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Home My WebLink About2026-04-08 Planning & Transportation Commission Agenda PacketPLANNING AND TRANSPORTATION COMMISSION Regular Meeting Wednesday, April 08, 2026 Council Chambers & Hybrid 6:00 PM Vice Chair Bryna Chang Remote Call In Location: 00000 Sandy Bay, Bay Islands, Honduras Planning and Transportation Commission meetings will be held as “hybrid” meetings with the option to attend by teleconference/video conference or in person. To maximize public safety while still maintaining transparency and public access, members of the public can choose to participate from home or attend in person. Information on how the public may observe and participate in the meeting is located at the end of the agenda. Masks are strongly encouraged if attending in person. 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. Commissioner names, biographies, and archived agendas and minutes are available at http://bit.ly/PaloAltoPTC. VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/91641559499) Meeting ID: 916 4155 9499 Phone: 1(669)900-6833 PUBLIC COMMENTS Public comments will be accepted both in person and via Zoom for up to three minutes or an amount of time determined by the Chair. All requests to speak will be taken until 5 minutes after the staff’s presentation. Written public comments can be submitted in advance to Planning.Commission@PaloAlto.gov and will be provided to the Commission and available for inspection on the City’s website three days before the meeting. Please clearly indicate which agenda item you are referencing in your subject line. Spokespersons that are representing a group of five or more people who are identified as present at the meeting at the time of the spokesperson's presentation will be allowed up to ten (10) minutes at the discretion of the Chair, provided that the non-speaking members agree not to speak individually. The Chair may limit Public Comments to thirty (30) minutes for all combined speakers. The Chair may reduce the allowed time to speak for Study Sessions and Action Items to two (2) minutes or less to accommodate a larger number of speakers. PowerPoints, videos, or other media to be presented during public comment are accepted only by email to Planning.Commission@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. CALL TO ORDER/ ROLL CALL AGENDA CHANGES, ADDITIONS AND DELETIONS The Chair or Commission majority may modify the agenda order to improve meeting management. PUBLIC COMMENT Members of the public may speak to any item NOT on the agenda. Three (3) minutes per speaker. CITY OFFICIAL REPORTS 1.Director's Report, Meeting Schedule, and Assignments STUDY SESSION Public Comment is Permitted. Three (3) minutes per speaker. 2.Study Session on Housing Element Program 6.5: Alternative Housing Program, Objective B. CEQA Status: Exempt Under CEQA Guidelines Section 15262. ACTION ITEMS Public Comment is Permitted. Applicants/Appellant Teams: Fifteen (15) minutes, plus three (3) minutes rebuttal. All others: Three (3) minutes per speaker. 3.PUBLIC HEARING / QUASI-JUDICIAL. 788-790 and 796 San Antonio Road [25PLN-00294]: Review of a Conceptual Plan to Rezone the Subject Properties From Service Commercial (CS) to a New Planned Community/Planned Home Zoning and to Redevelop the Site With an Eight-Story Mixed Use Building with 167 Residential Units, including 28 Below Market Rate Units, and Approximately 1,400 Square Feet of Ground Floor Retail Space, and Recommendation to Forward to the Architectural Review Board. CEQA Status: An Addendum to the Previously Certified Housing Incentive Program Expansion and 788 San Antonio Mixed Use Project EIR (SCH # 2019090070) is Currently Being Prepared. APPROVAL OF MINUTES Public Comment is Permitted. Three (3) minutes per speaker. 4.Approval of Planning & Transportation Commission Draft Summary & Verbatim Minutes of February 25, 2026 COMMISSIONER QUESTIONS, COMMENTS, ANNOUNCEMENTS OR FUTURE MEETINGS AND AGENDAS Members of the public may not speak to the item(s). ADJOURNMENT OTHER INFORMATION The materials below are provided for informational purposes, not for action or discussion during this meeting’s agenda. Written public comments may be submitted in advance and will be provided to the Commission and availible for public inspection on the City’s website three days before the meeting. A.Public Comment 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 Planning.Commission@PaloAlto.gov. 2.Spoken public comments using a computer will be accepted through the teleconference meeting. To address the Commission, 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. ◦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. 3.Spoken public comments using a smart phone will be accepted through the teleconference meeting. To address the Commission, download the Zoom application onto your phone from the Apple App Store or Google Play Store and enter the Meeting ID below. Please follow the instructions above. 4.Spoken public comments 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 Commission. 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: 916 4155 9499 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. Item No. 1. Page 1 of 2 Planning & Transportation Commission Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: April 8, 2026 Report #: 2604-6193 TITLE Director's Report, Meeting Schedule, and Assignments RECOMMENDATION Staff recommends that the Planning and Transportation Commission (PTC) review and comment as appropriate. BACKGROUND This document includes the following items:  Upcoming PTC Agenda Items PTC Meeting Schedule  PTC Representative to City Council (Rotational Assignments)  Commissioners are encouraged to contact Samuel Tavera (Samuel.Tavera@PaloAlto.gov) to notify staff of any planned absences one month in advance, if possible, to ensure the availability of a PTC quorum. PTC Representative to City Council is a rotational assignment where the designated commissioner represents the PTC’s affirmative and dissenting perspectives to Council for quasijudicial and legislative matters. Representatives are encouraged to review the City Council agendas (https://www.cityofpaloalto.org/City-Hall/City-Council/Council-Agendas- Minutes) for the months of their respective assignments to verify if attendance is needed or contact staff.  Prior PTC meetings are available online at https://midpenmedia.org/category/government/city- of-palo-alto/boards-and-commissions/planning-and-transportation-commission. UPCOMING PTC ITEMS April 29, 2026 Item 1 Item 1 Staff Report Packet Pg. 5 Item No. 1. Page 2 of 2 Parking Programs Update and Downtown Parking Modernization Initiatives 4103 Old Trace Road Tentative Map ATTACHMENTS Attachment A: 2026 PTC Meeting Schedule & Assignments AUTHOR/TITLE Jennifer Armer, Assistant Director Item 1 Item 1 Staff Report Packet Pg. 6 Planning & Transportation Commission 2026 Meeting Schedule 2026 Schedule Meeting Dates Time Location Status Planned Absences 1/14/2026 6:00 PM Hybrid Regular 1/28/2026 6:00 PM Hybrid Cancelled 2/11/2026 6:00 PM Hybrid Regular James 2/25/2026 6:00 PM Hybrid Regular Chang 3/11/2026 6:00 PM Hybrid Special James, Ji 3/25/2026 6:00 PM Hybrid Regular 4/8/2026 6:00 PM Hybrid Regular James 4/29/2026 6:00 PM Hybrid Regular 5/13/2026 6:00 PM Hybrid Regular Hechtman 5/27/2026 6:00 PM Hybrid Regular 6/10/2026 6:00 PM Hybrid Regular 6/24/2026 6:00 PM Hybrid Regular 7/8/2026 6:00 PM Hybrid Regular 7/29/2026 6:00 PM Hybrid Regular Hechtman 8/12/2026 6:00 PM Hybrid Regular 8/26/2026 6:00 PM Hybrid Regular 9/9/2026 6:00 PM Hybrid Regular 9/30/2026 6:00 PM Hybrid Regular 10/14/2026 6:00 PM Hybrid Regular 10/28/2026 6:00 PM Hybrid Regular 11/11/2026 6:00 PM Hybrid Cancelled 11/18/2026 6:00 PM Hybrid Special 11/25/2026 6:00 PM Hybrid Cancelled 12/9/2026 6:00 PM Hybrid Regular 12/30/2026 6:00 PM Hybrid Cancelled 2026 Assignments - Council Representation (primary/backup) January February March April May June Bryna Chang Allen Akin Bart Hechtman Kevin Ji Todd James Forest Peterson Todd James Forest Peterson Cari Templeton Bryna Chang Allen Akin Bart Hechtman July August September October November December Council Cari Templeton Bryna Chang Allen Akin Bart Hechtman Kevin Ji Summer Break Kevin Ji Todd James Forest Peterson Cari Templeton Bryna Chang Item 1 Attachment A - 2026 PTC Schedule & Assignments Packet Pg. 7 Item No. 2. Page 1 of 6 Planning & Transportation Commission Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: April 8, 2026 Report #: 2602-5972 TITLE Study Session on Housing Element Program 6.5: Alternative Housing Program, Objective B. CEQA Status: Exempt Under CEQA Guidelines Section 15262. RECOMMENDATION Staff recommends the Planning and Transportation Commission (PTC): 1. Receive presentation on the Alternative Housing Program Initial Analysis and preliminary implementation approaches (Attachment A); 2. Provide policy-level feedback on the alternative housing type(s) studied and the type that the PTC wants staff to prioritize for implementation and code development; and 3. Provide feedback on appropriate zoning districts and geographic areas where the preferred alternative housing type(s) may be most appropriate. EXECUTIVE SUMMARY The City of Palo Alto’s adopted 2023-2031 Housing Element1 includes Program 6.5, which directs the City to support a broader range of housing types to better meet the needs of residents across income levels, household sizes, and stages of life. Program 6.5 B: Alternative Housing Program specifically calls for the City to allow innovative and alternative housing models such as micro-unit housing, new shared, and intergenerational housing models and to evaluate existing zoning regulations that may be a challenge to the development of these alternative models. The project team completed an initial assessment of alternative housing to determine opportunities and challenges. This work included: Defining alternative housing models; Reviewing existing City regulations and policies; Evaluating approaches used by peer jurisdictions; and 1 https://paloaltohousingelement.com/wp-content/uploads/2024/08/Palo-Alto-Housing-Element.pdf Item 2 Item 2 Staff Report Packet Pg. 8 Item No. 2. Page 2 of 6 Identifying preliminary zoning and policy concepts that could facilitate these housing types in Palo Alto. This item is a study session and the purpose is to: Provide policy-level feedback on the alternative housing type(s) studied and the type that the Commission wants staff to prioritize for further analysis and code development; and Provide feedback on appropriate zoning districts and geographic areas where the preferred alternative housing type(s) may be most appropriate. Commission feedback will guide staff’s preparation of future zoning code amendments, ARB feedback, PTC consideration, and a subsequent recommendation to City Council. PROJECT DESCRIPTION The Alternative Housing Program is a City-initiated policy and regulatory effort intended to implement Housing Element Program 6.5 B. The program evaluates existing zoning standards, definitions, and development regulations and identifies potential amendments to the Palo Alto Municipal Code (PAMC) to support alternative housing types. The program establishes a framework for future zoning amendments that could allow and regulate alternative housing types citywide or in specific geographic areas and does not involve approval of a specific development project. Any future code amendments would be subject to additional public review, PTC and City Council consideration, and environmental review. BACKGROUND Housing Element Program 6.5 is intended to research and support the development of context- specific alternative and innovative housing product. Program 6.5 directs the City to: Allow innovative housing structures, such as micro-units, new shared, and intergenerational housing models, to support the housing needs of aging adults, students, and lower income residents; Identify locations where density limits may constrain alternative housing and modify or eliminate the maximum dwelling units per acre standards as appropriate; and Make recommendations to the City Council and amend the zoning ordinance as directed. Rationale for Alternative Housing The Housing Element, through research and subsequent analysis, clearly demonstrates the need for more diverse housing stock in Palo Alto. Key factors that support this rationale include: Housing affordability pressures, with a significant share of households spending more than 30 percent (and in many cases more than 50 percent) of income on housing; Overcrowding, particularly among renter households and lower-income residents, compounded by a limited supply of larger and more flexible rental units; Item 2 Item 2 Staff Report Packet Pg. 9 Item No. 2. Page 3 of 6 Demographic change, including a growing population of older adults seeking smaller, accessible, and well-located housing options; and Household diversity, including single-person households, students, essential workers, large households, and multigenerational families whose needs are not well served by a housing stock dominated by single-family homes. In 2021, more than 60 percent of housing units in Palo Alto were single-family homes, underscoring the importance of expanding housing choices beyond the City’s traditional formats. Housing Element Program 6.5 B was crafted to address these concerns and amend the City’s current regulations to facilitate the development of alternative housing types that would cater to the needs of the identified demographic. Summary of work completed to date As described further in the Analysis section below, and in Attachment A, City staff and the project consultants have: Developed working definitions for micro-housing, shared housing, and intergenerational housing based on State law, building codes, federal guidance, and stakeholder input; Reviewed existing City policies and regulations, including the Comprehensive Plan, Housing Element, Coordinated Area Plans, and the PAMC, to identify both opportunities and constraints; Conducted stakeholder interviews with architects, developers, housing advocates, and other practitioners experienced in alternative housing; and Identified appropriate geographic locations in the City for alternative housing types. As a next step, the project team will evaluate alternative housing approaches and built examples from other jurisdictions in the region to identify policies and regulations that Palo Alto can consider, to facilitate alternative housing production in the City. Additionally, the project team is evaluating the feasibility of incorporating senior housing into the City’s assessment of alternative housing models. This analysis will consider both market-rate and income-restricted options, aging-in-place needs, access to senior services, and potential incentives that could facilitate the development of senior housing. ANALYSIS In order to implement Housing Element Program 6.5 B, staff evaluated three alternative housing types: micro-housing, shared housing, and intergenerational housing. These housing types differ in physical form, operational characteristics, and target populations, but share common policy goals related to affordability, efficient land use, and housing diversity. A detailed analysis of the housing types researched, examples of researched housing developed in the region, and the different geographic areas in the City that are best suited for alternative housing types can be found in Attachment A: Program 6.5 B: Alternative Housing Program - Initial Analysis. Micro-Housing Item 2 Item 2 Staff Report Packet Pg. 10 Item No. 2. Page 4 of 6 Micro-housing generally consists of self-contained dwelling units that are smaller than conventional studio apartments, typically ranging from approximately 250 to 350 square feet. Units include a private bathroom and kitchenette and are most commonly developed in multifamily or mixed-use buildings. Shared Housing Intergenerational Housing Zoning and Geographic Considerations Are served by high-quality transit, including Caltrain stations and frequent bus corridors; Provide access to daily needs, services, parks, and community facilities; and Item 2 Item 2 Staff Report Packet Pg. 11 Item No. 2. Page 5 of 6 Allow or anticipate higher-density residential or mixed-use development. Potentially suitable zoning districts and planning areas include Pedestrian and Transit-Oriented Development (PTOD) areas, Downtown and California Avenue, the San Antonio Road Area, Housing Element focus areas, and North Ventura Coordinated Area Plan (NVCAP) area. Key Policy PTC Feedback Requested The following feedback will guide the next phase of work: 1. Policy-level feedback on the alternative housing type(s) studied and the type that the Commission wants staff to prioritize for further analysis and code development; and 2. Appropriate zoning districts and geographic areas where the preferred alternative housing type(s) may be most appropriate. FISCAL/RESOURCE IMPACT While there is no immediate fiscal impact and the project is currently funded through the General Fund FY 2026 Adopted Budget, staff anticipates that incorporating feedback from the Planning and Transportation Commission may require additional analysis and code development. At this time, the project team expects this work can be accommodated within the existing scope and resources, including the approved professional services agreement with Placeworks, Inc. However, if the scope expands beyond current assumptions, additional resources may be required and will be evaluated as part of future phases. STAKEHOLDER ENGAGEMENT As part of the analysis for the Alternative Housing Program, the project team conducted interviews with architects, developers, housing advocates, and other practitioners. The feedback received is included on pages A1-A11 of the Alternative Housing Program Initial Analysis (Attachment A). A dedicated project webpage3 has been launched and is accessible through the City’s website; the webpage will serve as the primary platform for ongoing project updates. Public notice of the study session was provided in accordance with the City’s standard noticing procedures for Planning and Transportation Commission meetings. While no formal public comment is required for this item, any public input received will be transmitted to the Planning and Transportation Commission and City Council, as appropriate. ENVIRONMENTAL REVIEW This study session is informational in nature and the actions recommended in this report are exempt from review under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15262: A project involving only feasibility or planning studies for possible future actions that has not been approved, adopted, or funded would not have significant impact on the environment. ATTACHMENTS 3 Alternative Housing Program – City of Palo Alto, CA Item 2 Item 2 Staff Report Packet Pg. 12 Item No. 2. Page 6 of 6 Attachment A: Program 6.5 B: Alternative Housing Program – Initial Analysis AUTHOR/TITLE: Item 2 Item 2 Staff Report Packet Pg. 13 City of Palo Alto Memo 1 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 Palo Alto Alternative Housing Program: Study Session: Planning and Transportation Commission Housing Element Program 6.5(B) Alternative Housing Program: Opportunities and Challenges This Opportuni/es and Challenges Memorandum include background informa/on, analyses, and poten/al approaches to the City of Palo Alto Alterna/ve Housing Project (Project). The Project will par/ally implement Palo Alto Housing Element (HE) Program 6.5. This memorandum is composed of the following sections: 1.Overview and Summary 2.Deﬁning “Alterna/ve Housing” 3.Exis/ng City of Palo Alto Regula/ons 4.Challenges to Alterna/ve Housing 1.Overview and Summary HOUSING ELEMENT PROGRAM 6.5(B) The overall intent of HE Program 6.5 Alterna/ve Housing is to support alterna/ve housing products such as large-family units, single-room occupancy units, suppor/ve and transi/onal housing, and managed living units. This memo includes analyses and preliminary approaches related speciﬁcally to Implemen/ng Objec/ve B of Program 6.5, which states: §Allow innova/ve housing structures, such as micro unit housing and new shared and intergenera/onal housing models, to help meet the housing needs of aging adults, students, and lower-income individuals citywide. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 14 City of Palo Alto Memo 2 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 §To the extent that density presents a constraint on development of alterna/ve housing types, iden/fy sites where elimina/on of maximum dwelling units per acre is appropriate. §Make recommenda/ons to City Council and follow up with an ordinance to change local zoning regula/ons as directed. Research completed as part of the 2023-2031 Housing Element indicates the need for alterna/ve housing due to mul/ple interrelated demographic condi/ons, including: §Inaccessible housing. Housing is increasingly unaﬀordable in Palo Alto. In 2018, 17 percent of all households were cost burdened, or spent more than 30 percent of monthly income on housing.1 Over 14 percent of households were severely cost burdened or spent more than 50 percent of their income on housing.2 §Overcrowding. Average household size has increased steadily in Palo Alto, from 2.3 persons per household (pph) in 2000, to 2.5 pph in 2013, and to 2.6 pph in 2020.3 Overcrowding dispropor/onately impacts low-income households. It is exacerbated by the current lack of larger (three or more bedrooms) aﬀordable rental units. Approximately 3.5 percent of renters experience moderate overcrowding, compared to 0.9 percent of owners.4 The HE iden/ﬁes the area of Embarcadero Road northeast of Highway 101 and south of Alma Street as overcrowding hotspots. §Elderly popula7on. The percentage of elderly persons in Palo Alto has increased signiﬁcantly. Residents 65 years and older made up about 13 percent of the popula/on in 1980. In 2020, the elderly made up about 19 percent of the popula/on.5 §Large households. In 2020, Palo Alto was es/mated to have about 1,848 households with ﬁve or more members,6 represen/ng approximately seven percent of total households. 1 United States Department of Housing and Urban Development, Comprehensive Housing Affordability Strategy (CHAS), based on the 2014-2018 American Community Survey (ACS). 2 Ibid. 3 US Census 2000 and 2010, Department of Finance 2013, and 2016-2020 ACS five-year estimates (Table S1101). 4 U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release. 5 US Census 1980, 1990, 2000, 2010, 2010-2012 ACS three-year estimates, and 2016-2020 ACS five-year estimates (Table DP05). 6 2016 -2020 ACS five-year estimates (Table B25009). Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 15 City of Palo Alto Memo 3 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 There is a severe mismatch between the number of these families and the number of dwelling units sized to accommodate them. In 2021, tradi/onal single-family homes made up over 60 percent of all housing units built in Palo Alto, highligh/ng the importance of a diversiﬁed housing stock. PlaceWorks assessed the three alterna/ve housing models iden/ﬁed in Program 6.5(B), including micro housing, shared housing, and intergenera/onal housing. PlaceWorks reviewed exis/ng laws, building codes, and industry standards used to deﬁne each model and guide local polices. PlaceWorks also reviewed the City’s current regula/ons as well as relevant zoning approaches in other jurisdic/ons. Finally, PlaceWorks iden/ﬁed nonregulatory and regulatory challenges to construc/ng alterna/ve housing. This analysis is supported by interviews with nine stakeholders experienced and/or invested in alterna/ve housing, both locally and in general. The results of this outreach process are summarized in Appendix A of this document. SUMMARY This Memo iden/ﬁes three poten/al, preliminary approaches that the project team is considering to facilitate the development of alterna/ve housing. As will be seen, the housing models iden/ﬁed in Program 6.5(B) are diverse. However, research and stakeholder interviews completed as part of this project suggest all are supported by the following policy frameworks and geographies: §Flexible development standards. The small unit sizes, design challenges and required densi/es of micro housing and urban co-living projects generally require generous ﬂoor- area-ra/o (FAR) standards, high lot coverage allowances and reduced open space requirements. §Low parking minimums. Most exis/ng and approved alterna/ve housing projects in the Bay Area provide no oﬀ-street vehicle parking. Many are located in districts without parking minimums or with parking maximums. Architects and developers consulted stated that oﬀ- street parking requirements are signiﬁcant barriers to most alterna/ve housing. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 16 City of Palo Alto Memo 4 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 §Proximity to eﬃcient transit systems. The small units, shared spaces, and typical tenants that deﬁne alterna/ve housing are generally associated with car-free living. Relevant projects thrive on transit corridors and near transit sta/ons or hubs. §Highly resourced loca7ons. Alterna/ve housing typically includes limited common, private or recrea/onal open space, and either small or shared living spaces. As noted, projects are ocen occupied by zero-vehicle households. As such, these projects are best suited to sites within walking distance of public parks, grocery and retail, diverse services, medical facili/es and other community resources. The preliminary recommenda7on for loca7ons that are best suited for the implementa7on of Alterna7ve Housing models include: •California Avenue Pedestrian and Transit-Oriented Development (PTOD) Combining District. Mul/ple stakeholders iden/ﬁed the PTOD as appropriate for alterna/ve housing and the target of PAMC amendments. •South of Forest Area Coordinated Area Plan (SOFA 1 CAP). The 2000 SOFA 1 CAP included City approval of 160 new dwelling units and 30,000 square feet of retail and oﬃce space in a 9-block area. This land use vision, which includes a public park and childcare facility, is consistent with alterna/ve housing. •San Antonio Road Area. The ongoing San Antonio Road Area Plan is an opportunity to zone for alterna/ve housing as part of a larger community vision consistent with such housing. There is a strong demand for mid-rise mul/family projects in the area, and city’s proposed vision for the area includes adding new public and private resources to support new housing. •ROLM Housing Element Focus Area. This HE focus area includes mul/ple housing opportunity sites. Although not currently fully-resources, this focus area will beneﬁt from the community vision, policies and future implementa/on of the adjacent San Antonio Road Area Plan. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 17 City of Palo Alto Memo 5 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 2.Deﬁning “Alternative Housing” There is agreement among stakeholders consulted on this project, as well as relevant research and policy, that there are no standard deﬁni/ons of the alterna/ve housing products iden/ﬁed in HE Program 6.5(B). The following ini/al descrip/ons are based on various building codes, State laws, federal policies, and stakeholder input. MICRO UNIT HOUSING “Micro unit housing” or “micro housing” refers to housing products with mul/ple dwelling units that typically do not exceed 350 square feet. Related terms include “eﬃciency housing,” “eﬃciency apartments,” “micro apartments,” and “/ny homes.” Exis/ng laws and regula/ons primarily regulate individual “micro units” rather than development models that contain them. Micro Units There is no standard size threshold beyond which a tradi/onal “dwelling unit” or studio becomes a “micro unit.” However, the following codes regulate minimum dwelling unit size in California: §Interna/onal Building Code (IBC) Sec/on 1208.4, Eﬃciency Dwelling Units. This sec/on establishes that “Eﬃciency Dwelling Units” shall have a living room of not less than 190 square feet (sf), and that such units shall: •Be provided with a separate closet. •Be provided with a kitchen sink, cooking appliance and refrigerator, each having a clear working space of not less than 30 inches (762 mm) in front. •Be provided with a separate bathroom containing a water closet, lavatory, and bathtub or shower. §California Health and Safety Code (HSC) Sec/on 17958.1. This sec/on establishes that local governments may “permit eﬃciency units for occupancy by no more than two persons which have a minimum ﬂoor area of 150 square feet, and which may also have par/al kitchen or bathroom facili/es, as speciﬁed by the ordinance.” Per this code, a jurisdic/on shall not: (1)Limit the number of efficiency units in an area zoned for residential use and located within one-half mile of public transit or where there is a car-share vehicle Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 18 City of Palo Alto Memo 6 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 within one block of the efficiency unit. (2)Limit the number of efficiency units in an area zoned for residential use and within one mile of a University of California or California State University campus. (3)For purposes of this subdivision, any requirements related to density, setbacks, lot coverage, or height restrictions established by local ordinance are not considered a limit on the number of efficiency units. §California Residen/al Code (CRC) Sec/on R304.5, Eﬃciency Dwelling Units. States that Eﬃciency Dwelling Units shall have a living room of not less than 220 square feet of ﬂoor area. An addi/onal 100 square feet of ﬂoor area shall be provided for each occupant of such in excess of two. Two architects consulted as part of this analysis stressed that achieving livable micro units that agract a wide market is diﬃcult within the minimal space parameters of the IBC. This is consistent with an Urban Land Ins/tute (ULI) survey of developers of micro housing, which found “…that a micro unit with less than 200 square feet was too small, that a unit with 375 square feet was too large, and that something in the 275- to 300-square foot range was op/mal…”7 This is about the size of a typical hotel room. Based on stakeholder input and na/onal research, this analysis assumes that a recommended local deﬁni/on for “micro unit” is a dwelling unit of 250 -350 square feet, inclusive of a required, separate bathroom and func/oning kitchenege, with interior space dimensions that comply with IBC standards. Accessory Dwelling Units (ADU) are some/mes categorized as micro housing. However, because ADUs are regulated in Chapter 18.09 of the Palo Alto Municipal Code (PAMC) and are not included in Housing Element Program 6.5(B), they are not included in this analysis and are not recommended to be included in the deﬁni/on of “micro unit” housing. Mul-family Micro Housing Mul/family micro housing, or micro apartments, refers to residen/al or mixed-use projects with ﬁve or more individual micro units. Not all units in these projects must be micro units. Input 7 Urban Land Institute, 2015, The Macro View and Micro Units, Page 25. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 19 City of Palo Alto Memo 7 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 from design stakeholders and review of recent projects indicate that mul/family micro housing projects are typically two to six-story structures designed to maximize density on small sites in walkable, transit-oriented neighborhoods. Stakeholders and research suggest that the loca/on of micro housing is a key component of this housing model. As unit space decreases, so does the need to build such units in highly resourced loca/ons. In a summary of walkability and loca/on, one legal researcher of micro housing wrote: “The shrinking of space within private homes may be oﬀset by external ameni/es.”8 Poten/al sites for micro housing in Palo Alto are discussed further in this memo. Mul/family micro housing is agrac/ve to college students, early-career professionals, teacher s, healthcare and service workers, and single-person households earning at low to moderate in come levels who seek aﬀordable, well-located housing with access to jobs, transit, and ameni/es. As described by one architect, these may be “young professionals who put a premium on vibrant and convenient loca/ons.” Ac/ve re/rees are also agracted to convenience and walkability. Car-free residents and those who rely on public transit or ac/ve transporta/on ﬁnd these units par/cularly appealing, as they are typically located in downtown or transit-oriented communi/es. Built Example The Rise at Berkeley. This project is located at 2025 Kala Bagai Way in downtown Berkeley. It in cludes 48 single- or double-occupancy micro studios ranging from 350 to 427 square feet. The project is situated on a 3,700 square-foot lot, resul/ng in a density of 570 units per acre. Common open space is provided in the form of a landscaped roocop garden. The project does not include vehicle parking. October 2025 lis/ngs include a 427 square-foot studio for $1,236/month and a 359 square-foot studio for $999/month. 8 Infranca, John, Stanford Law & Policy Review, Vol.25, Housing Changing Households: Regulatory Challenges For Microunits And Accessory Dwelling Units, page 86. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 20 City of Palo Alto Memo 8 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 Detached Micro Housing Detached micro housing refers to a range of housing products commonly referred to as “/ny homes.” The 2021 Interna/onal Residen/al Code, Appendix AQ,, deﬁnes “/ny house” or “/ny home” as “a dwelling that is 400 square feet (34 m2) or less in ﬂoor area excluding locs.” According to the California Department of Housing and Community Development, /ny homes may be permanent or mobile.9 Mul/family micro housing is typically considered a higher and beger use of urban land than free-standing detached micro housing. Moreover, City staﬀ and local housing advocates stressed there is less priori/za/on and poten/al for detached micro housing in Palo Alto than for micro apartments. Thus, this analysis focuses on mul/family micro housing. SHARED HOUSING “Shared housing” is an umbrella term for residen/al projects in which mul/ple private dwelling units share one or more communal spaces. A recent trio of assembly bills (AB 682, AB 1551, and AB 2334) added shared housing projects to the types of projects eligible for density bonuses if they provide aﬀordable units or senior housing. Per AB 682, the following deﬁni/ons are included in Government Code Sec/on 65915 (7) (A) (i)): §“Shared housing building.” “A residen/al or mixed-use structure, with ﬁve or more shared housing units and one or more common kitchens and dining areas designed for permanent residence of more than 30 days by its tenants. The kitchens and dining areas within the shared housing building shall be able to adequately accommodate all residents.” §“Shared housing unit:” “…one or more habitable rooms, not within another dwelling unit, that includes a bathroom, sink, refrigerator, and microwave, is used for permanent residence, that meets the “minimum room area” speciﬁed in Sec/on R304 of the California Residen/al Code and complies with the deﬁni/on of “guestroom” in Sec/on R202 of the California Residen/al Code.” 9 California Department of Housing and Community Development, May 9, 2016, INFORMATION BULLETIN 2016-01 (MH, FBH, SHL, MP/SOP, RT, OL)- Revised Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 21 City of Palo Alto Memo 9 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 §“Student housing development:” “… a development that contains bedrooms containing two or more bedspaces that have a shared or private bathroom, access to a shared or private living room and laundry facili/es, and access to a shared or private kitchen.” Palo Alto has adopted these deﬁni/ons and incorporated these products into PAMC Sec/on 18.15.030, Density Bonuses. California code allows ci/es to expand or restrict local deﬁni/ons beyond “the agributes of a shared housing building beyond the state deﬁni/on.” Expanding the deﬁni/on of shared housing allows ci/es to capture other federally iden/ﬁed housing models that are consistent with the goals of Program 6.5(B). The U.S. Department of Housing and Urban Development (HUD) deﬁnes shared housing broadly, as “a living arrangement in which two or more unrelated people share a house or apartment,”10 HUD stresses that “[shared housing] is an aﬀordable living arrangement…in urban areas with high housing costs.”11 The City of Palo Alto is consistent with this characteriza/on. HUD iden/ﬁes “cohousing” and “co-living” as formal variants of shared housing. Cohousing Cohousing refers to a development with private, self-contained units clustered around shared space to form inten/onal communi/es. According to the Cohousing Associa/on of the United States, cohousing is not a ﬁnancial or legal model. It is a descrip/ve term for “an inten/onal, collabora/ve neighborhood that combines private homes with shared indoor and outdoor spaces designed to support…community life.”12 Cohousing projects may include for-sale or for- rent units and may be organized formally as a co-op or a homeowner’s associa/on. Units are typically fully ameni/zed, with shared spaces dedicated to recrea/on and communal ac/vity. According to a prominent developer and designer of cohousing projects consulted as part of this project, these developments are valuable “go-betweens” that agract poten/al residents 10 U.S. Department of Housing and Urban Development, Office of Policy Development and Research, June 2021, Insights Into Housing and Community Development Policy, Assessments of Shared Housing in the United States. 11 Ibid. 12 The Cohousing Association of the United States, Cohousing.org, accessed April 23, 2025. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 22 City of Palo Alto Memo 10 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 interested in living in small communi/es rather than single-family homes or large mul/family projects. Co-housing agracts families, older adults, re/rees, and intergenera/onal households who seek long-term stability, collabora/on, and a strong sense of community. These residents value shared responsibility, social interac/on, and the ability to par/cipate in decision-making within an inten/onal neighborhood. Built Example Pleasant Hill Cohousing. At 2200 Lisa Lane in Pleasant Hill, CA. This is a suburban co-housing community on a 2.2-acre site. Developed in 2001, the community includes 32 townhouse-style homes that are individually owned condominiums managed under a homeowners associa/on. The community emphasizes environmental sustainability and social connec/on, featuring energy-eﬃcient green building design and shared facili/es such as a common house with a full kitchen, dining and gathering spaces, a workshop, organic garden, kiln, pool, and hot tub. Residents regularly share community meals two to ﬁve /mes per week, suppor/ng a coopera/ve lifestyle among households of all ages. Co-Living Co-living is an urban housing model in which individuals rent private, ocen furnished rooms in mul/family buildings that contain shared common spaces. HUD stresses that co-living “Frequently target[s] adult professionals in high-demand housing markets.”13 Common shared facili/es include kitchens, dining areas, living areas, and/or recrea/onal areas. Similar to micro housing, co-living appeals to college students, early-career professionals, teachers, essen/al workers, and single-person households who priori/ze aﬀordability, ﬂexibility, and convenience. Co-living residents ocen prefer furnished, well-located housing in transit- accessible areas that enable independent yet socially connected living. Together, these housing models oﬀer diverse, community-oriented, and againable housing op/ons that meet the needs of residents seeking connec/on, aﬀordability, and eﬃciency in high-cost urban areas. 13 U.S. Department of Housing and Urban Development, Office of Policy Development and Research, June 2021, Insights Into Housing and Community Development Policy, Assessments of Shared Housing in the United States. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 23 City of Palo Alto Memo 11 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 Built Examples 1900 Broadway. This 595,440 square-foot apartment building is located above the 19th Street BART sta/on in downtown Oakland. It contains 451 market rate units. A por/on of the units are co-living suites, each with four private bedrooms, two shared bathrooms, and fully equipped common living and kitchen spaces. Leases are per bedroom. Some bedrooms are furnished with expandable furniture. As of October 2025, bedroom leases in shared suites started at approximately $1,700/month. Poet’s Place Co-Living. This project is on San Pablo Avenue in Berkeley’s transit rich West Berkeley Commercial (C-W) District. The four-story, mixed-use building contains 42 private rooms, each with a private bathroom. A community kitchen and balcony are provided on each ﬂoor. The rooms operate under Berkeley’s Group Living Accommoda/ons (GLA), deﬁned as “A building or por/on of a building designed for or accommoda/ng Residen/al Use by persons not living together as a Household. According to the architect, the project was “designed as a prototype for a new housing type for UC Berkeley grad students and as a model for the greater Bay Area in addressing the housing crisis.” The project includes no vehicle parking. INTERGENERATIONAL HOUSING The United States Census deﬁnes “mul/genera/onal household” as a household that consists of at least two adult genera/ons. “Mul/genera/onal” and “intergenera/onal” are considered interchangeable terms. There are two common approaches to intergenera/onal housing: (1) programmed intergenera/onal housing and (2) mul/genera/onal households. Programmed Intergenerational Housing Programmed intergenera/onal housing refers to projects designed to support speciﬁc popula/ons of older and younger adults from diﬀerent families. These developments typically include eligibility requirements intended to facilitate successful cohabita/on and: §Provide for safety, health, and the necessi/es of life. §Promote programs that increase coopera/on and interac/on between people of diﬀerent generations. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 24 City of Palo Alto Memo 12 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 §Enable all ages to support each other in rela/onships that beneﬁt both individuals.14 As is the case with shared housing, California code establishes specific parameters for this housing model that can be expanded in a local deﬁni/on. §California Civil Code Sec/on 51.3.5 deﬁnes “intergenera/onal housing” as developments that consist of units for senior ci/zens (55 or older), caregivers, or transi/on-age youths (Individuals aged 18 to 24 who are either current or former foster or homeless youth). Residents of these projects typically share features such as common rooms, dining areas, recrea/onal spaces, and gardens. These projects are typically publicly subsidized and built by nonproﬁts or aﬀordable housing developers. Intergenera/onal housing appeals to residents across genera/ons who seek connec/on, mutual support, and stability within an inclusive community environment. Seniors beneﬁt from companionship, safety, and reduced isola/on, while younger residents gain ﬁnancial relief through aﬀordable living opportuni/es, and young families beneﬁt from everyday assistance such as childcare or household support through intergenera/onal interac/on. Caregivers may also live on-site to provide addi/onal assistance and strengthen community rela/onships. These communi/es integrate shared ameni/es and social programming to foster mutual support and enhance the well-being of residents of all ages. Approved Example 4300 San Pablo Avenue. The City of Emeryville recently approved the ﬁrst intergenera/onal aﬀordable housing development in California at 4300 San Pablo Avenue, located on a City- owned site and treated as an emergency shelter under the City’s zoning regula/ons. The property is owned by the City and formerly served as the City’s Recrea/on Center, consis/ng of portable oﬃce structures. Since 2019, the site has been temporarily used for emergency shelter and related opera/ons. The development will deliver 68 units of 100 percent aﬀordable intergenera/onal apartment homes serving seniors, caregivers, and transi/on-age youth. The project is classiﬁed as an “emergency shelter ” use, the project is not subject to residen/al 14 Harvard University, Joint Center for Housing Studies, 2024, Healthier Lives Across Generations, A Blueprint for Intergenerational Living Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 25 City of Palo Alto Memo 13 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 density limits or open space requirements, nor does it trigger any development bonuses or require oﬀ-street parking. Multigenerational Households Mul/genera/onal households refer to dwelling units sized and designed to accommodate all members of households with two or more adult genera/ons. Based on HE data and programming, this refers to aﬀordable rental units with three or more bedrooms in Palo Alto. The need is supported by HCD: “Due to the limited supply of adequately sized units to accommodate larger households, large families ocen face signiﬁcant diﬃculty in loca/ng adequately sized, aﬀordable housing.”15 Palo Alto HE Program 6.2, Family Housing and Large Units, calls for the City to “Research and implement incen/ves to encourage larger units, such as FAR exemp/ons for three or more- bedroom units, and crea/on of family-friendly design standards.” Therefore, this project does not assess approaches to mul/genera/onal households. STATE DEFINITION AND RHNA Whether alterna/ve housing units count toward a jurisdic/on’s regional housing needs alloca/on (RHNA) is an ongoing topic of concern. The California Department of Housing and Community Development (HCD) uses the U.S. Census Bureau’s deﬁni/on of “housing unit” in its regional housing needs determina/on (RHND) and RHNA processes. Per this deﬁni/on, a unit is “A house, an apartment, a mobile home, a group of rooms, or a single room that is occupied (or if vacant, is intended for occupancy) as separate living quarters.” Alterna/ve housing products such as individual microunits or separate units in shared living projects are consistent with this deﬁni/on and would count toward Palo Alto’s RHNA requirement. Other shared housing, such as co-living group units or programmed intergenera/onal housing, may be more consistent with the Census Bureau’s deﬁni/on of “group quarters,” which are “places where people live or stay in a group living arrangement that is owned or managed by an 15 California Department of Housing and Community Development, Building Blocks webpage, https://www.hcd.ca.gov/planning-and-community-development/housing-elements/building-blocks/large-families- and-female-headed-households, accessed April 29, 2025. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 26 City of Palo Alto Memo 14 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 organiza/on providing housing and/or services for the residents.” This concern was raised at a 2022 hearing of the Assembly Commigee on Local Government, regarding Assembly 682. Commigee members stressed that the cohousing units envisioned in the bill may not be eligible to count toward a local government’s RHNA target. HCD is currently reconsidering the role of group quarters in the RHNA process. In California’s Housing Future 2040, The Next Regional Housing Needs Alloca/on (RHNA) (April 2024) HCD evaluates the role of group quarters in the RHNA process, and the poten/al for credi/ng a wider range of housing types. According to the report, “some group quarters represent an essen/al form of housing that the state has an interest in incen/vizing. Crea/ng a more nuanced process for determining which group quarters are counted in the RHND can help ensure that the state is fully accoun/ng for the housing need and leveraging the RHNA process to incen/vize key housing types.” Although no ac/on has been taken, the report outlines a series of recommended statutory changes to adjust how group quarters are treated in the RHNA process. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 27 City of Palo Alto Memo 15 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 3. Existing City of Palo Alto Regulations There is precedent for suppor/ng alterna/ve housing in exis/ng City of Palo Alto land use and housing policies and regula/ons. LAND USE AND COMMUNITY DESIGN ELEMENT The Land Use and Community Design Element of the 2030 Comprehensive Plan priori/zes a mix of housing types. Although no policies refer directly to “alterna/ve housing,” many are consistent with HE Program 6.5(B). These include: § Policy L-2.3: As a key component of a diverse, inclusive community, allow and encourage a mix of housing types and sizes, integrated into neighborhoods and designed for greater aﬀordability, par/cularly smaller housing types, such as studios, co-housing, cogages, clustered housing, accessory dwelling units, and senior housing. § Program L2.4.5: Update the municipal code to include zoning changes that allow a mix of retail and residen/al uses, but no oﬃce uses. The intent of these changes would be to encourage a mix of land uses that contributes to the vitality and walkability of commercial centers and transit corridors. § Program L2.4.7: Explore mechanisms for increasing mul/family housing density near mul/modal transit centers. § Program L2.4.8: Iden/fy development opportuni/es for below-market rate and more aﬀordable market-rate housing on publicly owned proper/es in a way that is integrated with and enhances exis/ng neighborhoods. § Policy L-2.5: Support the crea/on of aﬀordable housing units for middle- to lower-income level earners, such as City and school district employees, as feasible. HOUSING ELEMENT Chapter 5, Goals & Policies of the 2023-2031 Housing Element includes policies that support the development of alterna/ve housing and the approaches to facilita/ng alterna/ve housing iden/ﬁed in this memo. These include: Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 28 City of Palo Alto Memo 16 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 §Policy 2.1: Increase opportuni/es for aﬀordable housing development through use of ﬂexible development standards. §Policy 2.2: Enhance incen/ves that expand development standard concessions and other inducements oﬀered as tools to facilitate the development of more aﬀordable housing, with a mix of aﬀordability levels within mixed-income housing. §Policy 2.3: Achieve a diversity of rental and homeownership opportuni/es, including apartments, townhomes, condominiums, single-family houses, and accessory dwelling units, micro-units and alterna/ve housing op/ons to accommodate the housing needs of all socioeconomic segments of the community. §Policy 3.3: Priori/ze funding for the acquisi/on of housing sites near public transit and services, the acquisi/on and rehabilita/on or replacement in exis/ng housing, and the provision for housing-related services for aﬀordable housing. NORTH VENTURA COORDINATED AREA PLAN The development of micro , shared, and/or intergenera/onal housing in the 2024 North Ventura Coordinated Area Plan (NVCAP) would par/ally support the NVCAP’s overarching Housing and Land Use goal: “Add to the City’s supply of mul2-family housing, including market rate, aﬀordable, “missing middle” and senior housing in a walkable, mixed use, transit-accessible neighborhood, with retail and commercial services, open space, and possibly arts and entertainment uses.” In addi/on, the rela/vely high-density land use districts in the NVCAP, shown in Table 1, would work to accommodate alterna/ve housing. TABLE 1 NVCAP DEVELOPMENT STANDARDS Land Use Density (du/acre) Maximum Height (ft) FAR Allowable Districts High-Density Mixed Use 61-100 65 3.0:1 NV-MXH Medium-Density Mixed Use 31-70 55 2.0:1 NV-MXM Low-Density Mixed Use 3-17 35 0.5:1 NV-MXL High-Density Residential 61-100 65 3.0:1 NV-R4 Medium-Density Residential 16-30 45 1.5:1 NV-R3 Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 29 City of Palo Alto Memo 17 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 AFFORDABLE HOUSING FUND Palo Alto’s Aﬀordable Housing Fund (AHF) was established “to provide ﬁnancial assistance for the development, acquisi/on and rehabilita/on of housing aﬀordable to extremely low, very low-, low-, and moderate-income households that live or work in the City.” The AHF Guidelines, amended via resolu/on by the City Council in 2025, are not land use regula/ons. However, the document includes language that highlights Palo Alto’s commitment to accessible alterna/ve housing. Sec/on C, Eligible Housing Types, Projects, and Ac2vi2es, iden/ﬁes “Shared housing, co-housing, mobile home parks and other special or innova/ve housing products” as one of the groups of housing approaches that “Aﬀordable Housing Fund revenues will primarily be used to assist.”16 All three alterna/ve housing products deﬁned in this memo are consistent with this group of approaches. Amending local land use regula/ons to further support these approaches would remove signiﬁcant barriers to the fulﬁllment of AHF objec/ves. PALO ALTO MUNICIPAL CODE This sec/on iden/ﬁes only direct references to alterna/ve housing products in the PAMC. There are many exis/ng PAMC regula/ons that are relevant to alterna/ve housing, both as opportuni/es for implementa/on and challenges to produc/on. These will be explored in the following sec/ons of this document. Micro Housing Micro housing is not deﬁned in PAMC Sec/on 18.04, Deﬁni/ons. There are two references to “eﬃciency unit” in PAMC Sec/on 18.04. One is under deﬁni/on (4)(A), as a type of unit allowed by the State of California as an ADU. The second is under deﬁni/on (135) “Studio dwelling unit, eﬃciency dwelling unit” means a dwelling unit consis/ng of a single habitable room for living and sleeping purposes, plus ancillary kitchen and bath facili/es. 16 City of Palo Alto, March 24, 2025, City of Palo Alto Affordable Housing Fund Guidelines. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 30 City of Palo Alto Memo 18 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 There is one direct reference to micro housing in the PAMC. Table 1 of PAMC Sec/on 18.52.040, Oﬀ-Street Parking, Loading and Bicycle Facility Requirements, states that one parking space per micro unit is required, the same requirement for studio units and 1-bedroom units. A table nota/on states: “A ‘micro unit’ as used herein means a residen/al unit of 450 square feet or less.” Parking standards for “micro units” are documented in the City’s past planning record. A 2018 Staﬀ Report to the Planning & Transporta/on Commission recommends conduc/ng a public hearing for a series of drac zoning amendments. One of the amendments is the addi/on of oﬀ- street parking standards for micro units, set at one space per unit. Unlike the current PAMC, the 2018 drac table nota/on does not quan/fy the size of micro units. It states that the parking standard would be reduced to 0.5 spaces per micro unit on parcels “within one-half mile radius of a major ﬁxed rail transit sta/on.” This reduc/on is not included in the current PAMC. Shared Housing “Shared housing” is not deﬁned in PAMC Sec/on 18.04. However, Sec/on 18.04 includes the following uses characterized by group living and/or shared facili/es: § (35) “Convalescent facility” means a use other than a residen/al care home providing inpa/ent services for persons requiring regular medical agen/on but not providing surgical or emergency medical services. § (124) “Residen/al care home” means use of a dwelling unit or por/on thereof licensed by the state of California or county of Santa Clara, for care of up to six persons, including overnight occupancy or care for extended /me periods, and including all uses deﬁned in Sec/ons 5115 and 5116 of the California Welfare and Ins/tu/ons Code, or successor legisla/on. § (135.5) “Suppor/ve housing” means housing with no limit on length of stay, that is occupied by target popula/ons, as deﬁned by Sec/on 53260(d) of the California Health and Safety Code, and that is linked to on- or oﬀ-site services that assist the suppor/ve housing residents in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community. Suppor/ve housing shall be considered a residen/al use of property and shall be subject only to those restric/ons that Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 31 City of Palo Alto Memo 19 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 apply to other dwellings of the same type in the same zone. Suppor/ve housing programs may use residen/al care homes wholly or as a part of their overall facili/es As previously noted, the PAMC also includes deﬁni/ons consistent with recent State density bonus laws. These include the following (full deﬁni/ons not repeated here): §"Shared housing building" §"Shared housing unit” §“Student housing development" Per the PAMC, “For purposes of calcula/ng a density bonus granted pursuant to this sec/on for a shared housing building, "unit" means one shared housing unit and its pro-rated share of associated common area facili/es.” Intergenerational Housing Intergenera/onal housing is not deﬁned or regulated in PAMC Title 18. However, PAMC Sec/on 9.74.010, Discrimina2on Against Families with Minor Children In Housing, states “The overall eﬀect of such discrimina/on is to encourage the ﬂight of families from the city, resul/ng in the decline of stable, intergenera/onal neighborhoods, the closure of schools, and the reduc/on of social and recrea/onal services for children and their families.” This language indicates that accommoda/ng intergenera/onal families is an ongoing priority in Palo Alto, and that implementa/on of HE Program 6.5(B) is consistent with at least one of the City’s social and quality of life objec/ves. PAST PROJECT APPLICATIONS The City has received a limited number of applica/ons for micro housing and other alterna/ve project types over the past decade. Although none have been built as originally submiged, the en/tlement processes indicate both developers’ interest and City’s recep/veness to such projects. Two examples include: Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 32 City of Palo Alto Memo 20 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 §2755 El Camino Real.17 In September 2016, staﬀ recommended that the City Council conduct a preliminary review of a project to develop a half-acre property with high-density, mul/family housing. The project included 60 small units and 45 parking spaces, 26 of which would be provided via a “puzzle parking” lic system. The project did not conform to any nearby zoning and was labeled a poten/al “pilot for micro housing.” One councilmember suggested that the City needed a zoning classiﬁca/on that allows for micro units and highlighted the idea of a “residen/al, low car impact project.” Staﬀ presented three op/ons that “could achieve the applicant ’s basic objec/ves,” including crea/ng a “Pilot Project” in the PF Zone District, crea/ng a “micro housing combining district overlay,” and modifying Pedestrian and Transit Oriented Development Combining District regula/ons for the project. Community feedback ranged from support for micro housing to concern over market viability and traﬃc impacts. The project was approved with an addi/onal 20 parking spaces (65 total) parking in 2018, and via the addi/on of a Workforce Housing (WH) Combining District to the exis/ng Public Facili/es (PF) Zoning District. The ﬁnal building, with 57 dwelling units, completed construc/on and received occupancy in May 2024. §955 Alma Street.18 In May 2021, an applicant made a request for a Council Prescreening to consider a proposal to rezone a site in the SOFA 2 area from RT-35 to Planned Community/PHZ and redevelop the site with a four-story, mixed-use development with 36 “innova/on micro studio residences” averaging 342 square feet (sf). The applicant requested a 30 percent parking reduc/on and lic parking. Some residents praised the project and its loca/on near the Caltrain Sta/on, sta/ng the units were suitable for young people and those without cars. Others ques/oned whether it would truly provide more aﬀordable op/ons, while some highlighted that it was out of context with the neighborhood and did not ﬁt on the small site. The project was never submiged for formal review. 17 City of Palo Alto, City Council Staff Report, ID# 7152, September 12, 2016. 18 City of Palo Alto, City Council Staff Report, ID# 12020, May 18, 2021. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 33 City of Palo Alto Memo 21 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 4. Challenges to Alternative Housing The following discussion is based primarily on input from stakeholders consulted on this project and analysis of other jurisdic/ons’ approaches. There is general agreement that developing alterna/ve housing faces mul/ple nonregulatory and local regulatory barriers. There are also poten/al approaches to overcoming each of these challenges, as outlined in the following sec/on of this memo. NONREGULATORY CHALLENGES The following poten/al challenges were iden/ﬁed by one or more stakeholders. They are also consistent with exis/ng research and ini/al analysis for this project. Each will inﬂuence the poten/al for alterna/ve housing in Palo Alto. § Financial Feasibility. Developers of cohousing, designers of micro housing and the housing ﬁnance expert consulted for this project highlighted current ﬁnancial challenges that may inﬂuence the construc/on of alterna/ve housing as much as local regula/on. These include lack of market demand, high interest rates, liability and insurance costs and construc/on costs. Stakeholders stressed the diﬃculty of acquiring lending for all but the largest mul/family projects, as well as liability concerns may result in extremely high insurance costs. The cohousing developer stated that developing co-ops and co-living projects as BMR developments is typically ﬁnancially infeasible. According to one designer, “In today’s ﬁnancial environment, only large projects can access the resources that allow you to dip into the lower income spectrum.” § Aﬀordability. There are concerns that housing costs do not decrease in propor/on to unit size. Rents for smaller units are not suﬃciently less than rents for slightly larger units, par/cularly when rents are based on BMR income limits instead of market/size of unit. However, most studies in markets such as San Francisco and Seagle indicate that micro housing is signiﬁcantly more accessible than tradi/onal housing. According to a May, 2025 study, the average rent of a micro unit in San Francisco was $1,888.00 and the average rent of a conven/onal unit was $3,516.00. In Seagle, the average rent of a micro unit was $1,289.00 versus a conven/onal rent of $2,388.00. § Community Concerns. As noted in this memo, past applica/ons for micro housing have been met with mixed opinions from community members. Due to their innova/ve nature, alterna/ve housing products are less familiar to members of all communi/es than Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 34 City of Palo Alto Memo 22 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 tradi/onal housing types. Stakeholder input and public feedback to past applica/ons indicates this may be a challenge in Palo Alto. As stated in the HE, most housing in Palo Alto consists of single-family homes. Mul/ple stakeholders stressed that residents have a history of strong, consistent opinions regarding housing development. This has resulted in predictability in many cases, but according to one stakeholder, may result in the community viewing micro housing or shared housing products as “a ‘step down,’ rather than a needed lateral approach.” LOCAL REGULATORY CHALLENGES Palo Alto land use and housing policies reviewed in this memo indicate broad support for local alterna/ve housing. The following sec/on outlines City of Palo Alto zoning, development and design standards that may impede the construc/on of alterna/ve housing. Lack of Formal Definitions As previously stated in this Memo, PAMC Sec/on 18.04 does not include formal deﬁni/ons of the three alterna/ve housing approaches included in HE Program 6.5(B). As a result, associated standards and regula/ons cannot be accurately assessed and adopted, and it is diﬃcult to iden/fy districts in which the uses may be allowed. Moreover, without deﬁni/ons, what cons/tutes each product is open to discre/on by applicants, City staﬀ and community members alike. This prevents streamlining and accuracy in the en/tlement process. Lack of Integra-on into Zoning Districts Associated with lack of deﬁni/ons, neither micro housing, shared housing or intergenera/onal housing is iden/ﬁed in land use tables of any zoning districts. Therefore, each applica/on for these uses requires an interpreta/on of appropriateness by the Director, per PAMC Sec/on 18.08.080. Moreover, the absence of alterna/ve housing in land use tables means that none of the models are referenced in the “Purposes” statements of any zoning district. The result is an overall lack of City priori/za/on of alterna/ve housing. Numerous Palo Alto policies encourage suppor/ng the construc/on of alterna/ve housing in various mul/family and commercial/mixed use districts. This language could be used to develop relevant, consistent PAMC purpose statements. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 35 City of Palo Alto Memo 23 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 Poten-ally Restric-ve FAR Maximums Stakeholder input collected for this analysis, review of other jurisdic/ons’ regula/ons and past project applica/ons suggest that FAR is a greater barrier to alterna/ve housing, speciﬁcally micro housing, than units/acre standards. PlaceWorks understands that the City of Palo Alto has recently adopted, or is currently studying, FAR increases through the Housing Incen/ve and Aﬀordable Housing Incen/ve programs, and in various study and focus areas. Most of these areas are consistent with the type of walkable, transit-oriented urban nodes that are amenable to alterna/ve housing. In addi/on, the PAMC includes mul/ple paths toward FAR increases. These include loca/ng sites on El Camino Real in CN and CS zones, FAR increases for housing developments of 3-10 units (PAMC 18.18.065), project loca/ons in speciﬁc assessment districts, and projects that include seismic or historic upgrades. Poten-ally Restric-ve Parking Requirements Nearly all stakeholders interviewed as part of this project stressed that alterna/ve housing, with typically smaller units or shared spaces, jus/ﬁes and requires reduced parking requirements. Designers and local housing advocates iden/ﬁed Palo Alto’s current oﬀ-street parking requirements as a poten/al barrier to these products. To facilitate this, there is also general agreement that these products should be built in walkable, transit rich areas. Lack of Targeted Objec-ve Design Standards Like most Bay Area jurisdic/ons with objec/ve design standards (ODS), Palo Alto’s ODS apply to development types included in state streamlining laws and those indica/ve of regional housing trends. These include: § Tradi/onal mul/family and mixed-use development forms, including townhouses (PAMC Chapter 18.24). § Townhome style mul/family projects, or “Village Residen/al” (PAMC Sec/on 18.13.060). As has been stressed, the alterna/ve housing products assessed in this memo are diverse in form and u/lity. Palo Alto’s current ODS do not account for these diﬀerences, which include, but are not limited to: § The impacts of micro unit size on external façade pagerns and massing breaks. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 36 City of Palo Alto Memo 24 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 § The diversity of scale and massing that may be associated with shared and micro housing. § Varied design and placement of private open spaces. § Changes to entryway standards resul/ng from primary common areas rather than individual units. § Design of common open spaces and shared facilities. § New standards for ligh/ng and ventilation. Poten-ally Restric-ve Open Space Requirements Mul/ple architects and planners interviewed for this project iden/ﬁed the City’s open space requirements as a barrier to past mul/family housing applica/ons, and a poten/al barrier to alterna/ve housing projects. They cited two poten/ally challenging components of the standards: § The minimum usable open space minimum, set at 150 sq./c. per unit in most high-density and commercial mixed-use districts. § The existence of mul/ple, interrelated open space standards, including: • Minimum usable open space. • Minimum common open space. • Minimum private open space. • Minimum landscape/open space coverage. As suggested, this group of standards can be restric/ve and is ocen perceived as overly complex. This may be par/cularly true for innova/ve housing types deﬁned by shared common and open areas, small units that maximize living areas, and designs that assume residents will u/lize surrounding open spaces and resources. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 37 City of Palo Alto Memo 25 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 38 City of Palo Alto Memo A-1 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 A P P E N D I X A A L T E R N A T I V E H O U S I N G P R O J E C T : S T A K E H O L D E R F E E D B A C K S U M M A R Y Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 39 City of Palo Alto Memo A-2 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 MEMORANDUM DATE June 18, 2025 TO Vishnu Krishnan, City of Palo Alto FROM Greg Goodfellow SUBJECT Alternative Housing Project: Stakeholder Outreach Summary Per Alterna/ve Housing Project Task 3. Stakeholder Outreach, PlaceWorks completed virtual interviews with individuals experienced and/or invested in alterna/ve housing, both locally and in general. PlaceWorks interviewed the following nine stakeholders as part of this task: Architects: § Ken Hayes, Owner, Hayes Group Architects § David Mogavero, Founder, Mogavero Architects § Isaiah Stackhouse, Principal + Design Director, Stackhouse de la Pena Trachtenberg Architects Palo Alto housing advocates: § Amie Ashton, Execu/ve Director, Palo Alto Forward § Carole Conn, Executive Director, Project Sentinel Land use consultants: § Jean Eisenberg, Owner, Lexington Planning Consultants § Janet-Smith Heimer, Founder, The Housing Workshop Stanford University: § Chris Wuthmann, Senior Director, Project Design and Construc/on, Real Estate Operations Cohousing developer: § Kathryn McCamant, President, CoHousing Solutions PlaceWorks focused on a series of topics in these interviews, some common to all interviews and others focused on stakeholders’ individual areas of exper/se. This Memo is organized by Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 40 City of Palo Alto Memo A-3 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 ques/ons and paGerns of responses to each. The content of this Memo includes comments as received, without fact-checking. What Is Your General Response to the Approach of Program 6.5(B)? 1. Palo Alto should facilitate alterna/ve housing at market rates. Program 6.5(B) does not explicitly state that alterna/ve housing should be developed as BMR op/ons. However, stakeholders noted that Program 6.5 includes language to support extremely-low income (ELI) households. Advocates and others expressed concern that restric/ng alterna/ve housing to BMR developments would decrease the primary beneﬁt of such housing, which is to provide aﬀordable, market rate op/ons. For example: § I am concerned about the ELI por/on of Program 6.5. Does it run through this? If it is only ELI housing it would only get developed by Eden, Bridge or other low-income housing developer. It would be too restric/ve. § I believe 100% that alterna/ve housing should be available to everyone, not just BMR. I hear from students, seniors and many others all the /me that low-cost MR units are needed. It is simply too diﬃcult to be ELI and live in Palo Alto. § I couldn’t be more adamant that the housing should be for everyone. Non-proﬁt developers are in a bind. If we’re serious, alterna/ve housing needs to be for all, and market developers need to take advantage of it. § It’s impossible to make the economics of small, BMR projects work. The typical threshold for feasibility of low-income, certainly ELI, is 60+ units. More commonly the economics work best at 80-120 units. The City needs to disconnect ELI from small projects. § You have mul/ple contexts in this Program, which is diﬃcult: Aﬀordability piece, student housing, overlap of transporta/on, and others. I would be careful not to aggregate things too much. Look at the poten/al from more of a market niche approach. § [On one aﬀordable housing project we designed in Palo Alto] two people on each commigee said “yes, it’s 100 aﬀordable, but median incomes here are so high that it’s not enough for me to support it.” § There aren’t many private developers who can do privately funded 100 aﬀordable projects. The highest aﬀordable project we have is maybe 25% aﬀordable, and that’s pushing the boundaries. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 41 City of Palo Alto Memo A-4 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 § The last thing you want to do is, out of good inten/ons, put too stringent of aﬀordability limits and then ﬁnd yourself with vacancies. 2. Priori/za/on of the three models in Palo Alto. Some stakeholder discussed the varying need for the three housing models in Palo Alto. There was considerable agreement that intergenera/onal housing appears less “alterna/ve” than the others, and that innova/on would result more from micro and shared housing § I am curious about intergenera/onal model. Just building 4–5-bedroom units does not seem very alterna/ve. I would rank micro hosing ﬁrst, then shared housing. Young people say it’s healthy and agrac/ve. It’s agracted young and old in San Jose. These are inten/onal communi/es and co-ops. These are run by non-proﬁts. People have a community with aligned values. § As for intergenera/onal, if you’re talking about 4–5-bedroom houses, it doesn’t ﬁt in the conﬁnes of this policy. It strikes me as slightly oﬀ. It assumes that families will grow into them organically. And it would be hardest from a market perspec/ve. § I found the City to be recep/ve to co-housing and coopera/ve living during Housing Element development. I think these are more consistent with the need for family-housing than micro housing would be. § [Promo/ng larger homes] for Intergenera/onal families seems oﬀ to me for Palo Alto. I would put this at the lower end of the priority for alterna/ve housing. I think solving the housing problem in its essence with density approaches is most sensible. § Micro housing and shared housing make sense in Palo Alto. There’s a huge amount of tech there, and Stanford. They also may have empty-nesters, and for-sale condo and co-ops pencil beger with today’s interest rates. We have a 90-unit condo complex in Lafayege that is for empty nesters, and two small condos using SB 6841 and SB 11232 mini lot. These would make sense in Palo Alto. 1 Streamlined approval for projects of 10 or fewer residential units on urban (multifamily) lots under 5 acres. 2 Expands SB 684 to vacant lots in single family zones, creating more affordable homeownership opportunities in neighborhoods that have traditionally excluded lower- and middle-income families Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 42 City of Palo Alto Memo A-5 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 What Neighborhoods, Nodes or Sites in Palo Alto Are Most Appropriate for Alterna-ve Housing? 1. Desired site agributes. All stakeholders interviewed as part of this project stated that alterna/ve housing belongs on sites in transit-oriented, walkable, highly resourced areas: § These products make no sense elsewhere [than TO sites]. The City placed /ny homes [RV parking] way out on Geng Road, but there was no access to anything. I hope we don’t add small aﬀordable units where no one can get anywhere. § Transit orienta/on is vital. Housing is one of two major cost burdens for the average household—the other is transporta/on: AAA says it’s about $12K a year to own an automobile. That may be equivalent to housing costs for some. So, if you can put people in a place where they don’t need a car, this may be more important than the cost of housing. This is the reason that low-cost, market rate housing in the right place, can be just as valuable as BMR housing. § If I/ one can live car free, that eliminates an en/re chunk of expenses. That is why transit orienta/on, access to jobs, walkability and access to schools are so important. § Poten/al residents on both ends of the spectrum, younger and older, are drawn to sites near food, public resources and transit. 2. Speciﬁc loca/ons. Stakeholder repeatedly iden/ﬁed several loca/ons that would be appropriate for alterna/ve housing. These include: § Downtown Palo Alto. Most stakeholders selected downtown Palo Alto ﬁrst, due to TOD, appropriateness for densi/es and other resources. § PTOD Overlay. One planner, one architect and one advocate selected the area within the California Avenue Pedestrian and Transit Oriented Development (PTOD) boundary as appropriate for alterna/ve housing. § California Ave/El Camino Real intersec/on. Two stakeholders said the area around this intersec/on represents the type of built environment that would accommodate micro and shared housing. § SOFA II: One stakeholder stated that policy in SOFA II policy calls for variety of housing types for a variety of residents. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 43 City of Palo Alto Memo A-6 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 § El Camino Real Focus Area: Two stakeholders highlighted recent upzoning in the ECR Focus Area as consistent with alterna/ve housing. What Are Current Barriers to Building Alterna-ve Housing in Palo Alto? 1. Culture and Community. Advocates, designers and developers stressed that facilita/ng alterna/ve housing will require a shic in local perspec/ve as much as, or more than, amended land use regulation: § Palo Alto has a strong, consistent belief system about development, which is a historical beneﬁt. However, this may translate into opposi/on to any kind of innova/on in housing, which could be viewed as a “step down” rather a purposeful, lateral change. § In my work in Palo Alto, I’ve found that even the most detailed design components can be used to jus/fy lack of support for the project. This does not bode well for alterna/ve approaches, which by their deﬁni/on are deﬁned by design changes. § The City needs to push the message that seniors and young people are open to new private spaces in order to live in walkable areas and shared communi/es. § There’s a culture where small units are “unlivable” and that anything less than 1:1 parking is unthinkable. The fact is, something like 425 sq c is not that small, and people want to live in those units and smaller ones. § People may have trepida/on about density because of the assump/on that it brings traﬃc and a diﬀerent “character” people, But we’ve seen that good projects will change this. 2. Density and intensity standards. All stakeholder agreed that Palo Alto’s current Floor Area Ra/o (FAR) standards have, and will con/nue to s/ﬂe construc/on of micro housing and shared housing: § We know how to solve this problem: eliminate density requirements citywide and reduce or eliminate parking requirements. We have increased FAR and other regula/ons to control intensity. This alone would facilitate these smaller and shared units. § Look at regula/on on El Camino Real. Some sites have a 50 foot height limit and decent lot coverage— they should be good. But the FAR of 0.7—that only allows a 1 story building— which negates the 50 foot height limit, and limits the chance of a density bonus project. § If the FARs aren’t corrected, it’s a non-starter. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 44 City of Palo Alto Memo A-7 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 § For our project, the barrier was not density, because there was no density limit. It was the FAR. State density bonus does require that if you don’t have a density limit, you must drop the hypothe/cal base project so that it complies with FAR, so FAR becomes proxy for density. § FAR results in risk. I’m hesitant to work on a project for more than three days if I don’t have guaranteed approval. Developers could spend hundreds of thousands or more on en/tlement in Palo Alto without clarity and security. If its that’s specula/ve, there aren’t many who will risk alterna/ve housing un/l FAR upzoning occurs. SB 330 will help with quick approval, but not more gross ﬂoor area. • FAR is going to have to change to meet housing element requirements. 3. Various zoning standards. Stakeholders iden/ﬁed the following series of speciﬁc zoning and design standards that may poten/ally restrict alterna/ve housing in Palo Alto: § Parking requirements. • Follow the path of Mountain View, Redwood City and Berkeley who have reduced or eliminated parking requirements. • By deﬁning micro units and units/bedrooms in shared complexes, you can jus/fy reduced parking requirements; currently 1 to 1 seems to be the limit. • Right now, PAMC parking rules do not reﬂect the combina/on of space and loca/on that characterize alterna/ve housing. § Planned Home Zoning • The PHZ process is too rigorous for these housing types. We found there was no project on our site that didn’t require the PHZ discre/onary process, which meant years of nego/a/ons with two separate commigees. § Objec/ve Design Standards • Light, air and step-back standards may be diﬃcult. Many downtown or walkable sites are small, very constrained, and mid-block many with no alleys. Micro units may be a workable way around ge~ng more units onto these sites, but my concern would be the lack of opportuni/es for adequate light and air. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 45 City of Palo Alto Memo A-8 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 • It may be diﬃcult to ﬁt shared housing into the massing, volume and other design standards that I’ve seen. • Micro units result in a more compressed façade, fenestra/on, eleva/on and private open space design that typical mul/family. § PAMC Sec/on 18.18.120 (“Shrink Wrap Rule”). • Two stakeholders are concerned that PAMC Sec/on 18.18.120 reduces incen/ve for owners of exis/ng buildings to take on the risk of developing innova/ve housing types. According to one stakeholder, this is signiﬁcant because so many sites downtown, where micro and shared housing are appropriate, are built out with noncompliant buildings that exceed the FAR for commercial. Before this, property owners wouldn’t hesitate to tear buildings down, because they could add that valuable commercial ﬂoor area back, which could then support housing on top. § Residen/al open space requirements. • Two stakeholders stated that a major challenge to micro and shared units will be the City’s open space minimums. • One stakeholder stated that the PAMC’s individual landscape coverage, usable open space, common open space and private open space minimums are too restric/ve and complex. § Live/work land use restric/ons. • One avenue may be revising live/work rules, which are associated with alterna/ve living and smaller units. The City has talked about live work in the past. Right now, it is prohibited except in PTOD overlay (California Pedestrian and Transit Oriented Development Combing District). PA should expand live-work allowance in key areas. § Local density bonus • I’m concerned that the way Palo Alto regulates controls density bonus will prohibit alterna/ve housing. The City has low densi/es, so it created the HIP/AHIP to increase it, rather than use State bonus. This is frustra/ng to developers who are used to the State process. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 46 City of Palo Alto Memo A-9 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 4. Financing and Feasibility. The architects and developer interviewed stressed that regardless of policy and regula/on, current ﬁnancial barriers will con/nue to restrict all housing development, especially alterna/ve housing: § The program calls for zoning amendments, but I’d suggest the bigger barrier to micro and shared housing is not zoning, but the state of ﬁnances. Even market rate products are s/ﬂed. The problem is more with the nature of ﬁnance; speciﬁcally, interest rates are high. People aren’t building as much market rate right now. § In today’s ﬁnancial environment, only large projects can access the resources that allow you to dip into the lower income spectrum. § Insurance and liability are huge obstacles to our cohousing projects. Our recent Berkeley project required $1.6M insurance, which is added to project construc/on costs and scares developers away. § We declined a shared housing project in Sacramento called Washington Commons, due to insurance costs and liability concerns. We wanted a WRAP insurance policy3, but they couldn’t do it. Too much tort liability. § As a cohousing developer, I’ve learned that no one builds small, for-sale inﬁll housing anymore. Their values hold, but there is no way we could make these projects work as ELI or BMR developments. What Zoning or Regulatory Approaches Could the City Take t o Advance Alterna-ve Housing? 1. Upzone broadly. Stakeholder noted the “surgical” approach to zoning amendments and stressed that the best way to facilitate alterna/ve housing is broad upzoning: § I just don’t think an overlay is the way to go, because we are naturally ge~ng these projects. Look at 660 University. Mostly studio/1 -bed. 400 to 800 sq feet. It just seems like upzoning more broadly would naturally get us more units. 3 Refers to a single "WRAP insurance program" that cover all participants in a construction project. These programs are typically either owner controlled, or contractor controlled. WRAP programs may save significant project costs due to reduced premiums and reduced costs of potential litigation Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 47 City of Palo Alto Memo A-10 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 § The City recently got rid of density on 25 parcels in EC Housing Focus Area the other night. It is ac/ons like that that are most helpful. § Three stakeholders referenced Berkeley as a prime local example of the value of upzoning to these housing types: • In [Berkeley] downtown, there is no FAR limit, no density limit and no parking requirement. It’s just a base project building envelope and density bonus on top. By- right project as long as you meet aﬀordability requirements. • Built examples: The Rise, on a compact 3,700-square-foot lot in downtown Berkeley; 570 units per acre. Studios from 350 sq. c. Studio 2000 Microunits: 82 studio a with parking for 40 bicycles. Twenty percent of the units are “below market rate” aﬀordable. “Sawtooth” façade allows for increased light and views. • The El Camino Focus Area: None of the projects that meet standards go to Council. Director Hearing approved. By far, /me is the number one barrier to housing, And ECR Housing Focus area projects are ge~ng done. Approved in 9 months. 2. Allow for design standards exemp/ons. § Sharing housing and cohousing is always easier to bring through review if there is a form- based code in place, rather than typical units/acre requirements. § Exemp/ons from, or targeted changes to, key design standards for alterna/ve housing. 3. Amend Live/Work. § One avenue may be revising live/work rules, which ae associated with alterna/ve living and smaller units. The City has talked about live/work in the past. Right now, it is prohibited except in PTOD overlay. PA should expand live/work allowance in key areas and expand the deﬁni/on. 4. Inclusionary Housing “Breaks.” The cohousing developer consulted stressed that inclusionary housing ordinances are diﬃcult for co-living, cohousing and other shared housing projects. § We can never make the actual low-income unit requirements work; we only pay in-lieu fees. These get added to the insurance and other costs. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 48 City of Palo Alto Memo A-11 Memo Planning and Transporta/on Commission/Architectural Review Board December 10, 2025 § Breaks from fee structure would help. § Reduced requirements for shared units, smaller average unit size or small unit thresholds. § IHO incen/ves for shared housing units with common spaces, such as more streamlining or design exemp/ons. 5. Amend the City’s Fee Structure. Mul/ple stakeholders pointed to the structure of development fees, both local and statewide, as a disincen/ve to altera/ve housing. § In Berkley co-housing has worked because fees are on a per-unit basis. This made our new Jewish Cohousing in Berkeley work. Residents will own their units and will share 8,700 square feet of communal space, including two kitchens, a terrace, courtyard, play area, bicycle and car garage, art studio and gym. § In Palo Alto, if you propose over 49 units, one chunk of fees takes a huge jump per unit. This is a major hurdle in fees that ocen impacts the number of units in our projects—we s/ck to 49. So maybe one approach could be that alterna/ve housing development are exempted from this rule. § In general, all fees I encounter are designed around larger, for sale homes rather than small, shared or other alterna/ve approaches. This has to change. 6. Reduce Parking Requirements. Nearly all stakeholders stressed the rela/onship between alterna/ve housing, travel habits and loca/on, and resul/ng need to rethink parking requirements to accommodate these models. Item 2 Attachment A - Program 6.5 B Alternative Housing Program Initial Analysis Packet Pg. 49 Item No. 2. Page 1 of 9 Planning & Transportation Commission Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: April 8, 2026 Report #: 2603-6148 TITLE PUBLIC HEARING / QUASI-JUDICIAL. 788-790 and 796 San Antonio Road [25PLN-00294]: Review of a Conceptual Plan to Rezone the Subject Properties From Service Commercial (CS) to a New Planned Community/Planned Home Zoning and to Redevelop the Site With an Eight-Story Mixed Use Building with 167 Residential Units, including 28 Below Market Rate Units, and Approximately 1,400 Square Feet of Ground Floor Retail Space, and Recommendation to Forward to the Architectural Review Board. CEQA Status: An Addendum to the Previously Certified Housing Incentive Program Expansion and 788 San Antonio Mixed Use Project EIR (SCH # 2019090070) is Currently Being Prepared. RECOMMENDATION Staff recommends that the Planning and Transportation Commission (PTC) take the following action: 1. Provide initial comments/feedback and forward the proposed project application to the Architectural Review Board (ARB) for review of the development plan. EXECUTIVE SUMMARY The applicant proposes to rezone the subject properties from Service Commercial (CS) to a new Planned Community/Home Zoning (PC/PHZ) and to redevelop the site with a mixed-use building featuring 167 residential rental units and approximately 1,400 square feet of ground floor commercial retail space. The project includes demolition of two existing commercial building, including a historic building, which was previously evaluated in an Environmental Impact Report (SCH # 2019090070) and approved for demolition on November 16, 2020, pursuant overriding considerations. Council reviewed a prescreening application for the currently proposed project on May 19, 2025. In accordance with Palo Alto Municipal Code (PAMC) Section 18.38.065(a), for a PC/PHZ rezoning the PTC must first review a conceptual plan, provide feedback, and recommend that the project be forwarded to the ARB for further formal review. The project will return to the PTC, following ARB review, for a formal recommendation to Council. PROJECT DESCRIPTION The preliminary schematic drawings, included in Attachment G, are conceptual, as is appropriate at this stage of project consideration. The project includes an eight-story mixed-use building that includes 167 Item 3 Item 3 Staff Report Packet Pg. 50 Item No. 2. Page 2 of 9 residential units (37 studios, 96 one-bedrooms, 34 two-bedrooms) and approximately 1,400 square feet of retail. Parking is provided within an at-grade, two-level parking garage accessed from Leghorn Avenue that includes 74 parking spaces. A separate certificate of compliance would be required as a condition of approval to merge the two existing lots and to create a 43,889-square-foot resulting parcel. A location map is included in Attachment A. Planned Community (PC/PHZ): The process for evaluating this type of application is set forth in PAMC Chapter 18.38. Planned Community 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. The findings for approval of a PC/PHZ are included in Attachment B. BACKGROUND Item 3 Item 3 Staff Report Packet Pg. 51 Item No. 2. Page 3 of 9 East: Office, Religious Use, Restaurant (GM) South: Oil Changers (CS) Special Setbacks:24-foot special setback along San Antonio Road Aerial View of Property: Source: Google Maps Land Use Designation & Applicable Plans/Guidelines Comp. Plan Designation:Service Commercial (CS) Zoning Designation:Service Commercial (CS) Yes Yes Yes Baylands Master Plan/Guidelines (2008/2005) El Camino Real Guidelines (1976) Housing Development Project Downtown Urban Design Guidelines (1993) South El Camino Real Guidelines (2002) Utilizes Chapter 18.24 - Objective Standards Individual Review Guidelines (2005) Within 150 feet of Residential Use or District Context-Based Design Criteria applicable SOFA Phase 1 (2000)SOFA Phase 2 (2003)Within Airport Influence Area Item 3 Item 3 Staff Report Packet Pg. 52 Item No. 2. Page 4 of 9 Item 3 Item 3 Staff Report Packet Pg. 53 Item No. 3. Page 4 of 9 Prior City Reviews & Action City Council:Prescreening May 19, 20251 PTC:None HRB:None ARB:None The City Council provided feedback on a prescreening application for the proposed development and rezoning on May 19, 2025. At the time, the proposed development included a proposed eight-story, 168-unit, residential rental development with 73 parking spaces. No retail was proposed at the time. Councilmembers were generally supportive of the overall height, density, and green roof design. They expressed significant concern over the lack of parking (though they expressed that they would consider additional information from a parking study and encouraged adding ride share options as well), asked for stepbacks on San Antonio and adjacent 800/808 San Antonio Road, and expressed that retail needed to be incorporated. Neighborhood Context This property is located within the boundaries of the proposed San Antonio Road Area Plan, as well as the Housing Incentive Program (HIP) area. Adjacent properties contain: The approved five-story mixed-use project at 800 San Antonio Road (which also recently applied to rezone under a new Planned Community/PHZ Zone District for a proposed eight-story building); The proposed eight-story residential rental project at 762 San Antonio Road to the south; and The approved four-story senior housing project to the north at 824 San Antonio Road. To the west, across San Antonio Road, are commercial uses within the general manufacturing (GM) Zone District, including a biomedical use, Immune-Onc Therapeutics (immediately across the street), and a multi-family residential use within a Planned Community Zone district (the Greenhouse residential development) at the intersection of Leghorn and San Antonio Road. Adjacent buildings are generally single-story buildings; however, the approved and pending residential projects vary between four and eight stories tall. ANALYSIS The proposed plans are conceptual in nature, as is required in accordance with PAMC Section 18.38.065 for this early hearing with the PTC. Therefore, the plans are still being reviewed by all departments. Through this hearing, staff is seeking the PTC’s recommendation to forward the conceptual project plans to the ARB for further development and review. Prior to any recommendation or decision approving any PC rezoning, the PTC and Council must make the approval findings set forth in Attachment B. Therefore, the required findings are provided for the PTC’s reference, though the findings do not need to be made at this time. Item 3 Item 3 Staff Report Packet Pg. 54 Item No. 3. Page 5 of 9 Consistency with the Comprehensive Plan, Area Plans, and Guidelines2 This property’s land use designation is Service Commercial. The Service Commercial Designation is described in the Comprehensive Plan as: “Facilities providing citywide and regional services and relying on customers arriving by car. These uses do not necessarily benefit from being in high volume pedestrian areas such as shopping centers or Downtown. Typical uses include auto services and dealerships, motels, lumberyards, appliance stores and restaurants, including fast service types…In some locations, residential and mixed-use projects may be appropriate in this land use category. Examples of Service Commercial areas include San Antonio Road, El Camino Real, and Embarcadero Road northeast of the Bayshore Freeway. Non-residential FARs will range up to 0.4. Consistent with the Comprehensive Plan’s encouragement of housing near transit centers, higher density multi-family housing may be allowed in specific locations.” The project site is considered an appropriate location for higher density multi-family housing since it is located within an area identified for higher density housing under the Comprehensive Plan. While the proposed density exceeds the highest density expressly stated in the Comprehensive Plan (40 du/ac), it is consistent with densities achievable under some state laws and the densities being discussed as part of the San Antonio Road Area Plan under development. Though neither of the two parcels were identified as housing inventory sites in the City’s adopted Housing Element, the City identified the site as part of a pipeline project with 102 units planned on this site, 16 of which would be affordable at a rate affordable to renters earning moderate income. The current proposal includes 167 units, 28 of which would be provided at a rate affordable to low income, exceeding this identified pipeline for the resulting parcel, though at a different income level. These additional units would assist the City in meeting the City’s Regional Housing Needs Allocation (RHNA). Zoning Compliance5 Staff has prepared an analysis of the proposed project’s consistency with the current Commercial Services (CS) zone district standards (Attachment C) to show how the project deviates from these standards. Most notably, the proposed project deviates from the existing CS Zoning in the following ways: Height: 89 feet where 50-foot height maximum is allowed (94 feet to top of rooftop equipment enclosure); Floor Area Ratio: 3.75 to 1 floor area ratio where 0.6 to 1 maximum is allowed (2.0 allowed under the housing incentive program); Lot Coverage: 67% lot coverage where 50% maximum is allowed (100% allowed per housing incentive program); Ground Floor Commercial: 1,385 square feet of commercial space currently proposed where minimum 6,583.35 square feet is required (mixed-use ground floor commercial Item 3 Item 3 Staff Report Packet Pg. 55 Item No. 3. Page 6 of 9 FAR of 15%); and Housing Density: 167 dwelling units/acre where 30 dwelling units/acre is allowed (no maximum density under the housing incentive program). Staff notes that the previously approved project at this site included approximately 107 dwelling units per acre, 1.97:1 floor area ratio, and 67% lot coverage, and 107 parking spaces for 102 units. PC Special Requirements The PC Special Requirements set forth in PAMC Section 18.38.150 apply because the project site is within 150 feet of a residentially zoned property or residential PC district. The adjacent property, 800/808-814 San Antonio Road is currently designated as PC-5622, which includes 75 residential condominium units. Both these special setback daylight plane requirements and Council’s feedback for buildings of this height within this area should result in step backs into the design at upper levels adjacent to 808 San Antonio Road. Stepbacks have been incorporated into the design at the corner of Leghorn and San Antonio Road consistent with Council’s feedback. Staff requests input from the PTC in regards to daylight plane and/or stepbacks, particularly in relation to the planned neighboring residential use, as the project moves forward to design with review with the ARB. Housing Incentive Program (HIP) This project is located within the area designated for use of the HIP. Housing projects within this area may exceed certain development standards, including floor area (up to 2.0:1 floor area ratio) and lot coverage (100% allowed) in addition to having no maximum density. However, the applicant is proposing to rezone the property in-lieu of developing the site in conformance with the HIP. Multi-Modal Access & Parking This project proposes a 40 percent parking reduction in comparison to the base requirements set forth in PAMC Chapter 18.52. Therefore, a Transportation Demand Management (TDM) plan is warranted to reduce vehicular trips and use of parking associated with the proposed project. A total of 74 parking spaces is proposed where 184 parking spaces would otherwise be required. This is a ratio of approximately 0.44 spaces per unit, and no parking for the propose commercial use. A TDM has been submitted for the project and is being reviewed by the City’s Office of Transportation. Overall, the applicant has decreased the total number of units by one unit and increased the parking count by one space. Some of the provided spaces are ride-share spaces and therefore not available for individual purchase by residents. Council expressed concerns about the proposed parking. Though additional information has been provided by the applicant in Attachment E to show why they believe the parking would be viable, the applicant has not made meaningful changes to the parking count in response to Council’s feedback. Item 3 Item 3 Staff Report Packet Pg. 56 Item No. 3. Page 7 of 9 Driveway access is provided from Leghorn Street, and this driveway will accommodate residential vehicles, consistent with the previous approval, while refuse pick-up will occur via a loading space located on Leghorn Street along the site’s frontage. In addition, Fire access is proposed to be provided from Leghorn Street; however, the proposed location is still being reviewed. Public transportation and multi-modal options in this neighborhood are limited and are important considerations for the coordinated area plan that is currently being developed for this corridor. The project as currently proposed maintains the 24-foot special setback, which is intended to provide space for these future improvements. 7 This provides a weighted calculation to incentivize developers to provide very-low and low-income units, rather than the moderate and ”workforce” units. Table 1 below calculates weighted values for the BMR units provided, equivalent to approximately 20.11%. This exceeds the minimum 20% required for a PHZ project. 788-790 and 796 San Antonio Road Below Market Rate Unit Calculation Income Level Area Median Income Weighted Value Number of Units % of Actual Units Weighted % Total Item 3 Item 3 Staff Report Packet Pg. 57 Item No. 3. Page 8 of 9 should be required as an additional public benefit of the project. The special setback restricts development within the first 24 feet of the property, but does not give the City rights to utilize that property without the benefit of an easement. FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT Daily Post on March 27, 2026, which is 12 days in advance of the meeting. Postcard mailing occurred on March 26, 2026, which is 11 days in advance of the meeting ENVIRONMENTAL REVIEW Item 3 Item 3 Staff Report Packet Pg. 58 Item No. 3. Page 9 of 9 ALTERNATIVE ACTIONS In addition to the recommended action, the Planning and Transportation Commission may: 1. Continue the item to a date uncertain, to return to PTC based on specific direction, before moving the project forward to the Architectural Review Board. Attachment A: Location Map Attachment B: Findings for Approval Attachment C: Zoning Comparison Table Attachment D: Historic Resources Evaluation Attachment E: Transportation Demand Management Plan and Applicant Provided Parking Information Attachment G: Development Program Statement and Development Schedule Attachment H: Project Plans 1 Liaison & Contact Information Tamara Harrison, AICP, Contract Planner Jennifer Armer, Assistant Director (951) 506-2061 (650) 329-2191 Tamara.Harrison@mbakerintl.com jennifer.armer@cityofpaloalto.org 1 Emails may be sent directly to the PTC using the following address: planning.commission@cityofpaloalto.org Item 3 Item 3 Staff Report Packet Pg. 59 24 15 15 15 24 ding 4 ilding 1 Building 1 Building 3 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 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95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 94.1' 73.8' 95.3' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 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148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 0.0' 275.9' 148.9' 242.4' 73.8' 94.1' 169.6' 60.1' 165.8' 60.0 ' 165.8' 60.2' 160.8' 60.0 ' 160.8' 107.0' 148.9' 105.9' 95.0' 129.4' 32.0' 74.4' .1' 149.9' 244.42' 197.0' 244.42' 171.8' 50.0' 169.6' 50.0 ' 9.3' 219.3' 90.1' 209.1' 89.2' 209.1' 94.1' 198.5' 93.2' 198.5' 98.7' 187.4' 21.3' 76.4' 187.4' 103.5' 178.2' 102.6' 178.2' 107.3' 172.2' 106 .7' 172.2' 147.6' 147.0' 34.3' 124.2' 136.6' 118.1' 159.4' 102.4' 27.9' 159.4' 219.8' 180.6' 126.6' 97.2' 107.4' 409.8'409.8' 180.6' 8' 4062 808- 814 796 800 809 777 790 801 799 797 795 821 815 824 816 788 780 762 4074 SAN ANTONIO ROAD LEGHORN STREET CS CS (AD) This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend Special Setback Frontages Park School abc Building Roof Outline Underlying Lot Line abc Easement abc Lot Dimensions Zone Districts abc Zone District Labels City Jurisdictional Limits: Palo Alto City Boundary Tree Highlighted Features 0' 73' Attachment A Location Map 788-796 San Antonio Road CITY OF PALO ALTO I NC O R P O R A TE D CALI FORNIA P a l o A l t o T h e C i t y o f APRI L 1 6 189 4 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Alto ekallas, 2025-04-30 08:22:38 (\\cc-maps\Encompass\Admin\Personal\Planning.mdb) Item 3 Attachment A - Location Map Packet Pg. 60 Attachment B Findings for Approval The Planning and Transportation Commission will need to make the following Findings for Approval of a Planned Community Zone District when the project returns for a formal recommendation: (a) 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. (b) Development of the site under the provisions of the PC planned community district will result in public benefits not otherwise attainable by the application of the regulations of general districts or combining districts. In making the findings required by this section, the Planning and Transportation Commission and City Council, as appropriate, shall specifically cite the public benefits expected to result from the use of the planned community district. (c) 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 3 Attachment B - Findings for Approval Packet Pg. 61 ATTACHMENT C ZONING COMPARISON TABLE 788 and 796 San Antonio Road, 25PLN-00294 Table 1: COMPARISON WITH CHAPTER 18.16 (CS DISTRICT) Residential Development Standards Regulation CS Requirement (w/HIP Zoning for reference only) Proposed PC Minimum Site Area, width and None No change depth San Antonio Road): 22,622 sf APN 147-03-042 (796 San Antonio Road): 21,267 sf Resulting parcel: 43,889 sf Approx. 1.00 acre Minimum Front Yard (Leghorn)10-foot special setback 25 feet Rear Yard 10 feet for residential portion of proposed project; none for commercial 10 feet Interior Side Yard 10 feet if abutting residential 10 feet, 1 inch Min. yard for lot lines abutting or opposite residential districts or residential PC districts 10 feet Applies, 10 feet provided Street Side Yard (San Antonio Road) 25 feet (special setback) 25 feet Max. Site Coverage 50% (21,944 sf) 100% for housing incentive program projects 67% (28,882 sf) Max. Building Height 50 ft or 35 ft within 150 ft. of a residential district (other than an RM-40 or PC zone) abutting Rooftop Garden allowed to exceed height by 12 ft. Stair and Elevator overrun allowed to minimum height feasible for access 89 feet to parapet 94 feet 2 inches to top of rooftop equipment Item 3 Attachment C - Zoning Comparison Table Packet Pg. 62 Mechanical equipment allowed to exceed height by 15 ft. Daylight Plane Daylight planes may be identical to the daylight plane requirements of the most restrictive residential district abutting (including residential PC) each such side or rear site line until intersecting the height limit otherwise established for the PC district. Must match existing PC Build-to-Lines 50% of frontage built to setback (1) 33% of side street built to setback (1) San Antonio Road: Complies Leghorn: None built to setback Residential Density 30 du/ac per CS Zone 40 du/ac per Housing Element No density maximum for Housing Incentive Program project 167.56 DU/AC (167 units proposed) Maximum Floor Area for HIP In no event shall the Director approve a commercial FAR that exceeds the standard in Table 4 of Section 18.16.060(b) or a total FAR (including both residential and commercial FAR) in excess of 2.0 3.75:1 (178,558 sf Total) 3.49:1 (151,488 sf Residential) 0.03:1 (1,385 sf Commercial) Minimum Useable Open Space 150 sf per unit Common Open Space Provided: ground level, courtyard, roof terrace = 13,471 sf Private Open Space: Typical 69 sf – 98.4 sf Average total per unit meets 150 sf min sf Minimum Mixed-use Ground Floor Commercial FAR 0.15:1(10) 6,583.35 sf or 1,500 sf (c) 1,385 sf (1) No parking or loading space, whether required or optional, shall be located in the first 10 feet adjoining the street property line of any required yard. (2) Any minimum front, street side, or interior yard shall be planted and maintained as a landscaped screen excluding areas required for access to the site. A solid wall or fence between 5 and 8 feet in height shall be constructed along any common interior lot line. (6) The initial height and slope shall be identical to those of the most restrictive residential zone abutting the site line in question. (10) In the CC(2) zone and on CN and CS zoned sites on El Camino Real, there shall be no minimum mixed use ground floor commercial FAR for a residential project, except to the extent that the retail preservation requirements of Section 18.40.180 or the retail shopping (R) combining district (Chapter 18.30(A)) applies. (c) A high-density residential or mixed-use project in the CS zone district, but not within the Ground Floor (GF) or Retail (R) combining districts, shall be required to replace only 1,500 square feet of an existing Retail or Retail-Like use. For the purposes of this partial exemption, high-density shall mean 30 or more dwelling units per acre Item 3 Attachment C - Zoning Comparison Table Packet Pg. 63 Item 3 Attachment C - Zoning Comparison Table Packet Pg. 64 Table 2: CONFORMANCE WITH CHAPTER 18.52 (Off-Street Parking and Loading) for Existing Commercial and Proposed Residential* Type Required Proposed Vehicle Parking 1/studio and 1- bedroom unit 2/2-bedroom or larger unit (note HIP allows 1.5 space per two bedroom or larger) First 1,500 sf of retail: none 184 spaces total 74 spaces for residential, no retail spaces provided (40% of total required spaces) Bicycle Parking 1 LT space per unit and 1 ST space per 10 units 167 LT spaces and 17 ST spaces 167 LT, ST none indicated though ST bike spaces appear to be provided on Leghorn Loading Space 1, for residential structures with >50 units 2 short term loading spaces and 1 long term loading space Item 3 Attachment C - Zoning Comparison Table Packet Pg. 65 imagining change in historic environments through design, research, and technology Page & Turnbull 788 SAN ANTONIO ROAD HISTORIC RESOURCE EVALUATION PALO ALTO, CALIFORNIA [16252H] PREPARED FOR: CITY OF PALO ALTO JUNE 5, 2020 Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 66 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California TABLE OF CONTENTS I. INTRODUCTION ...................................................................................................... 2 METHODOLOGY .................................................................................................................................... 2 II. EXISTING HISTORIC STATUS .............................................................................. 4 NATIONAL REGISTER OF HISTORIC PLACES ............................................................................................ 4 CALIFORNIA REGISTER OF HISTORICAL RESOURCES ............................................................................... 4 CALIFORNIA HISTORICAL RESOURCE STATUS CODE ............................................................................... 4 PALO ALTO HISTORIC INVENTORY .......................................................................................................... 4 DAMES & MOORE PALO ALTO HISTORICAL SURVEY UPDATE ................................................................. 5 III. BUILDING AND PROPERTY DESCRIPTION ....................................................... 6 SURROUNDING NEIGHBORHOOD ........................................................................................................ 8 IV. HISTORIC CONTEXT .......................................................................................... 10 PALO ALTO HISTORY ............................................................................................................................ 10 PENINSULA GARDEN FARMS ............................................................................................................... 12 THE CALIFORNIA CHRYSANTHEMUM GROWERS ASSOCIATION ........................................................... 14 V. PROJECT SITE HISTORY ...................................................................................... 23 SITE DEVELOPMENT ............................................................................................................................ 23 OWNERSHIP AND OCCUPANT HISTORY .............................................................................................. 25 VI. EVALUATION ....................................................................................................... 26 CALIFORNIA REGISTER OF HISTORICAL RESOURCES ............................................................................. 26 CHARACTER-DEFINING FEATURES ...................................................................................................... 28 INTEGRITY ............................................................................................................................................ 28 VII. CONCLUSION .................................................................................................... 30 VIII. REFERENCES CITED.......................................................................................... 31 Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 67 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 2 - I. INTRODUCTION This Historic Resource Evaluation (HRE) has been prepared at the request of the City of Palo Alto for the property at 788 San Antonio Road (APN 147-03-041). The property is owned by the California Chrysanthemum Growers’ Association, and is located at the southeast extent of the City of Palo Alto near the northwestern border of Mountain View in an unnamed neighborhood zoned for “service commercial” (CS) use. The subject property is a roughly square 22,622-square foot parcel at the northeast corner of the intersection of San Antonio Road and Leghorn Street (Figure 1). The parcel includes the subject property at 788 San Antonio Road, a concrete masonry unit commercial building constructed in 1953, as well as a portion of the neighboring building to the northeast, 796 San Antonio Road. 788 San Antonio Road is not currently listed in the National Register of Historic Places (National Register) or the California Register of Historical Resources (California Register). The subject property is also not currently listed on the City of Palo Alto Historic Inventory, and is not located within a registered historic district.1 Figure 1. Location of 788 San Antonio Road. Parcel boundary outlined in orange. Source: Google Earth, edited by Page & Turnbull. METHODOLOGY This report follows a standard outline used for Historic Resource Evaluation reports, and provides a summary of the current historic status, a building description, and historic context for the building at 788 San Antonio Road. The report includes an evaluation of the property’s individual eligibility for listing in the California Register of Historical Resources. The report does not include an evaluation of its eligibility for local designation or as a contributor to a historic district. 1 City of Palo Alto, Master List of Structures on the Historic Inventory, July 24, 2012. Electronic document at https://www.cityofpaloalto.org/civicax/filebank/documents/3504, accessed February 15, 2019. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 68 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 3 - Page & Turnbull prepared this report using research collected at local repositories, including the Palo Alto Development Service and Palo Alto Historical Association, as well as the San Francisco Public Library and various online sources including Ancestry.com, the California Digital Newspaper Collection, and the Online Archive of California. Key primary sources consulted and cited in this report include Palo Alto building permit applications, city and county directories, and historical newspapers. All photographs in this report were taken by Page & Turnbull during a site visit on January 31, 2019, unless otherwise noted. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 69 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 4 - II. EXISTING HISTORIC STATUS The following section examines the national, state, and local historical ratings currently assigned to 788 San Antonio Road. NATIONAL REGISTER OF HISTORIC PLACES The National Register of Historic Places (National Register) is the nation’s most comprehensive inventory of historic resources. Administered by the National Park Service, the National Register includes buildings, structures, sites, objects, and districts that possess historic, architectural, engineering, archaeological, or cultural significance at the national, state, or local level. 788 San Antonio Road is not listed in the National Register of Historic Places individually, or as a part of a registered historic district. CALIFORNIA REGISTER OF HISTORICAL RESOURCES The California Register of Historical Resources (California Register) is an inventory of significant architectural, archaeological, and historical resources in the State of California. Resources can be listed in the California Register through a number of methods. State Historical Landmarks and National Register-listed properties are automatically listed in the California Register. Properties can also be nominated to the California Register by local governments, private organizations, or citizens. The evaluative criteria used by the California Register for determining eligibility are closely based on those developed by the National Park Service for the National Register of Historic Places. 788 San Antonio Road is not listed in the California Register of Historical Resources individually, or as a part of a registered historic district. CALIFORNIA HISTORICAL RESOURCE STATUS CODE Property listed or under review by the State of California Office of Historic Preservation are assigned a California Historical Resource Status Code (Status Code) of “1” to “7” to establish their historical significance in relation to the National Register of Historic Places (National Register or NR) or California Register of Historical Resources (California Register or CR).2 Properties with a Status Code of “1” or “2” are either eligible for listing in the California Register or the National Register, or are already listed in one or both of the registers. Properties assigned Status Codes of “3” or “4” appear to be eligible for listing in either register, but normally require more research to support this rating. Properties assigned a Status Code of “5” have typically been determined to be locally significant or to have contextual importance. Properties with a Status Code of “6” are not eligible for listing in either register. Finally, a Status Code of “7” means that the resource has not been evaluated for the National Register or the California Register, or needs reevaluation. 788 San Antonio Road is not listed in the California Historic Resources Information System (CHRIS) database with a status code. The most recent update to the CHRIS database for Santa Clara County that lists the Status Codes was produced in April 2012. PALO ALTO HISTORIC INVENTORY The City of Palo Alto’s Historic Inventory lists noteworthy examples of the work of important individual designers and architectural eras and traditions as well as structures whose background is 2 California Office of Historic Preservation. Technical Assistant Bulletin No. 8: User’s Guide to the California Historical Resource Status Codes & Historic Resources Inventory Directory (Sacramento: California Office of State Publishing, 2004), electronic document at http://ohp.parks.ca.gov/pages/1069/files/tab8.pdf, accessed March 11, 2019. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 70 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 5 - associated with important events in the history of the city, state, or nation. The inventory is organized under the following four Categories: ▪ Category 1: An “Exceptional Building” of pre-eminent national or state importance. These buildings are meritorious works of the best architects, outstanding examples of a specific architectural style, or illustrate stylistic development of architecture in the United States. These buildings have had either no exterior modifications or such minor ones that the overall appearance of the building is in its original character. ▪ Category 2: A “Major Building” of regional importance. These buildings are meritorious works of the best architects, outstanding examples of an architectural style, or illustrate stylistic development of architecture in the state or region. A major building may have some exterior modifications, but the original character is retained. ▪ Category 3 or 4: A “Contributing Building” which is a good local example of an architectural style and relates to the character of a neighborhood grouping in scale, materials, proportion or other factors. A contributing building may have had extensive or permanent changes made to the original design, such as inappropriate additions, extensive removal of architectural details, or wooden façades resurfaced in asbestos or stucco.3 788 San Antonio Road is not listed in the Palo Alto Historic Inventory under any category. DAMES & MOORE PALO ALTO HISTORICAL SURVEY UPDATE Between 1997 and 2000, the consultant firm Dames & Moore, contracted by the City of Palo Alto, conducted a survey update which identified, recorded and evaluated properties for the National Register of Historic Places and California Register of Historical Resources. Office of Historic Preservation Department of Parks and Recreation (DPR) 523 forms were not prepared for all properties. The findings of the survey are summarized in Dames & Moore, Final Survey Report: Palo Alto Historical Survey Update, submitted to City of Palo Alto (February 2001). 788 San Antonio Road was not included in the Dames & Moore survey. 3 City of Palo Alto, “Palo Alto Historic Inventory,” electronic resource at https://www.cityofpaloalto.org/gov/depts/pln/historic_preservation/historic_registers/local_inventory.asp, accessed February 15, 2019. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 71 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 6 - III. BUILDING AND PROPERTY DESCRIPTION 788 San Antonio Road is a simple, one-story, concrete masonry unit commercial building on a concrete foundation with a rectangular footprint 50 feet wide and 124 feet long, and its long axis aligned east-west. The majority of the building’s roof is of a shallow domed shape or flat, but an asymmetrical side-gabled portion at the west side, with composition shingle roofing, an overhanging eave, and a cross-gabled ridge centered over the main entrance highlights the primary façade. Metal flashing folds a few inches over the roof edge of the flat-roofed portions of the building. Rectangular, multi-lite fixed and casement steel-sash windows are typical on all façades, and appear to be original. The exterior, concrete masonry unit walls are set in running bond and painted white. The building is set back approximately 40 feet from Leghorn Street to the south, and 50 feet from San Antonio Road to the west. It is surrounded on all sides by paved areas, with a parking lot serving the property to the west, vehicle circulation and parking areas to the south, the parking lot of the adjoining property to the east, and a driveway accessing the rear of 796 San Antonio Road to the north. Primary (West) Façade The primary (west) façade of the subject building faces San Antonio Road and features an anodized metal swinging entrance door with tinted glass, a wide sidelight with a metal mail slot, and flat, painted wood trim centered below the peak of the cross-gabled roof (Figure 2 and Figure 3). The entry is flanked on either side by paired typical windows with two-by-four configuration of panes, framed by slightly curved concrete blocks at either side (Figure 4). A wood plank shelf is mounted below each pair of windows, each supported by four square wood beams. The roof gable features tongue-and-groove wood siding. The slightly overhanging eave has a metal eavestrough affixed to the simple wood fascia board running the width of the façade. South Façade The south façade of the subject property faces Leghorn Street and includes three roll-up utility doors accessed by corresponding curb-cuts in the adjacent sidewalk (Figure 5). Four typical windows, with a four-by-three configuration of panes and slightly curved concrete units framing the sides, are spaced evenly in alternation with the utility doors. One small, narrow rectangular three-lite window sits to the immediate west of the westernmost utility door. The central utility door has a single, metal pedestrian door opening in its right side The roof is predominantly flat, with the asymmetrical gable of the western roof portion at the end closest to San Antonio Road. Rear (East) Façade The rear (east) façade of the subject property abuts the east parcel boundary, overlooking the parking lot of the neighboring property (Figure 6). It has no openings. North Façade The north façade of the subject property faces the neighboring building a 796 San Antonio Road, and overlooks a driveway accessing the rear of that building. The façade features seven fixed typical windows, with four-by-three configurations of panes, spaced evenly along its length. The roof is predominantly flat, with the asymmetrical gable of the western roof portion at the end closest to San Antonio Road (Figure 7). Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 72 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 7 - Figure 2. Primary (west) façade of 788 San Antonio Road, view northeast. Figure 3. Detail of primary façade entrance at 788 San Antonio Road, view northeast. Figure 4. Detail of windows, south side of primary façade, 788 San Antonio Road, view east. Figure 5. South façade of 788 San Antonio Road, view northeast. Figure 6. Rear (east) façade of 788 San Antonio Road, view northwest. Figure 7. North façade of 788 San Antonio Road, view southwest. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 73 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 8 - SURROUNDING NEIGHBORHOOD The neighborhood immediately surrounding the subject property is generally characterized by mid- twentieth-century commercial buildings lining the busy corridor of San Antonio Road (Figure 8 through Figure 13). Appropriate to the “service commercial” zoning of the area, these businesses are primarily oriented toward customers traveling by automobile, and thus provide on-site parking accessed by driveways from the main thoroughfare. There is a mix of automotive service providers, private office complexes, and health- and activity-focused businesses within the immediate vicinity of the subject property. Several of the office spaces appeared to be vacant at the time of the site visit. A multi-unit residential complex is set back from San Antonio Road to the west opposite the intersection with Leghorn Street. Figure 8. 796 San Antonio Road, view northeast. Figure 9. 800 San Antonio Road, view northeast. Figure 10. 795 and 796 San Antonio Road, view northwest. Figure 11. Residential development at 777 San Antonio Road, set back from traffic. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 74 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 9 - Figure 12. 780 San Antonio Road, view southeast. Figure 13. 2595 Leghorn Street, view northwest. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 75 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 10 - IV. HISTORIC CONTEXT PALO ALTO HISTORY The earliest documented settlement of the Palo Alto area was by the Ohlone people, who resided in the area at the time of Gaspar de Portola's 1769 expedition through the territory. Permanent European settlements were established beginning in 1777, with Junipero Serra's founding of the Mission Santa Clara de Asis within what is now the city of Santa Clara, with lands extending into the area which is now Palo Alto. During its years of operation, the mission relied on the labor of indigenous workers belonging to the region's Ohlone tribes and other groups. Following secularization of the Spanish missions beginning in 1833, the Spanish, and later Mexican, government carved the area into large ranchos which contained portions of land that became Palo Alto. These included Rancho Corte Madera, Rancho Pastoria de las Borregas, Rancho Rincon de San Francisquito, and Rancho Riconada del Arroyo de San Francisquito.4 These land grants were honored in the cession of California to the United States, but did not long remain intact as parcels were subdivided and sold throughout the rest of the nineteenth century. The subject property was within the lands of the Rancho Rincon de San Francisquito, and was later subdivided into a parcel south of Charleston Road, owned in 1876 by “P. Swallow” (Figure 14).5 The earliest township within the current boundaries of Palo Alto was called Mayfield. In 1882, railroad magnate and California politician, Leland Stanford, purchased 1,000 acres adjacent to Mayfield to add to his large estate in northwestern Santa Clara County. Figure 14: Detail view of “Santa Clara County Map Number One” by Thompson & West, 1876. Red square notes approximate location subject property. Source: David Rumsey Historical Map Collection, edited by Page & Turnbull. 4 Ward Winslow and Palo Alto Historical Association, Palo Alto: A Centennial History (Palo Alto, CA: Palo Alto Historical Association, 1993), 12-17. 5 Thompson & West, “Santa Clara County Map No. 1,” Historical Atlas Map of Santa Clara County, California, (San Francisco: Thompson & West, 1876). Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 76 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 11 - Stanford’s vast holdings became known as the Palo Alto Stock Farm. On March 9, 1885, Leland Stanford Junior University was founded through an endowment act by the California Assembly and Senate. Using their Stock Farm land, the Stanfords began constructing the university, which ultimately opened in 1891. Stanford decided in 1894 to found the town of Palo Alto with help from his friend Timothy Hopkins of the Southern Pacific Railroad. Hopkins purchased and subdivided 740 acres of the former Rancho Rinconada del Arroyo de San Francisquito.6 Known as both the Hopkins Tract and University Park, the townsite was bounded by the San Francisquito Creek to the north, the railroad tracks and Stanford University campus to the southwest, and Embarcadero Road to the south The development of a local streetcar in 1906 and the interurban railway to San Jose in 1910 facilitated access to jobs outside the city and to the university campus, encouraging more people to move to Palo Alto. In July 1925, Mayfield was officially annexed into the city of Palo Alto. Palo Alto was one of the first California cities to establish a City Planning Commission (CPC). In 1917, this advisory commission considered zoning matters in order to control new development and design within the city. The CPC’s purview included regulations on signage, public landscaping and lighting, and residential development. Palo Alto’s regulations on development have resulted in its relatively low density and consistent aesthetic. However, zoning controls in the early part of the twentieth century contributed to racial segregation in the city and the exclusion of certain groups from residential areas. Several neighborhoods were created with race-based covenants, which persisted until this practice was ruled unconstitutional in 1948.7 The depression of the 1930s impacted the design, construction, and financing of buildings across the nation. While Palo Alto did suffer through the Great Depression, new development did not come to a halt. The United States government assisted in providing housing through several programs, and architectural journals and newspapers showed a substantial amount of construction between 1931 and 1944.8 The United States’ involvement in World War II brought an influx of military personnel and their families to the San Francisco Peninsula. When the war ended, Palo Alto saw rapid growth. Many military families who had been stationed on the Peninsula, who those who worked in associated industries chose to stay. Palo Alto’s population more than doubled from 16,774 in 1940 to 33,753 in 1953.9 Stanford University was also a steady attraction for residents and development in the city. The city greatly expanded in the late 1940s and 1950s, as new parcels were annexed to house new offices and light industrial uses. As a result of this development, the city evolved somewhat beyond its “college town” reputation.10 Palo Alto’s city center greatly expanded in the late 1940s and 1950s, gathering parcels that would house new offices and light industrial uses and lead the city away from its “college town” reputation. Small annexations continued into the 1970s, contributing to the discontinuous footprint of the city today. Palo Alto remains closely tied to Stanford University; it is the largest employer in the city. The technology industry dominates other sectors of business, as is the case with most cities within Silicon 6 City of Palo Alto. Comprehensive Plan 2030. Adopted by City Council, November 13, 2017. Electronic document at https://www.cityofpaloalto.org/civicax/filebank/documents/62915, accessed January 2, 2019, section L-3. 7 Dames & Moore, “Final Survey Report – Palo Alto Historical Survey Update: August 1997-August 2000” prepared for the City of Palo Alto Planning Division, February 2001,1-7. 8 Ibid., 1-9. 9 “Depression, War, and the Population Boom,” Palo Alto Medical Foundation- Sutter Health, accessed March 24, 2016, http://www.pamf.org/about/pamfhistory/depression.html. 10 City of Palo Alto, Comprehensive Plan 2030, section L-4. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 77 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 12 - Valley. Palo Alto consciously maintains its high proportion of open space to development and the suburban feeling and scale of its architecture.11 PENINSULA GARDEN FARMS Throughout Palo Alto’s early decades of growth as a town, the lands surrounding the subject property remained a largely agricultural stretch between that city and the small settlement growing around the transportation stop at Mountain View to the southeast. Until the early 1950s, the area surrounding the location of the subject property was dominated by large agricultural tracts with low- density settlement. The building at 788 San Antonio Road was constructed within tract No. 219 of the “Peninsula Garden Farms,” a subdivision that was marketed as early as the mid-1920s for buyers seeking one- to two-acre lots where they could raise market gardens, poultry, or rabbits.12 By 1927, advertisers offered that, with the expansion of Palo Alto to the northwest and Mountain View to the southeast, buyers could soon subdivide and sell their acre lots for a profit. An April 16, 1927 advertisement suggested: At the rate property is being developed on the San Francisco Peninsula, it will be only a short time before your acre here will become too valuable for ranching. Then you can subdivide your acre into city lots and sell each lot for more than the cost of an acre today.13 Despite this early marketing effort, aerial photographs of the area show that the pattern of development along San Antonio Road between Charleston and Middlefield roads consisted primarily of large, rural lots and open space rather than the city lots developers envisioned (Figure 15). The subject building was among the earliest commercial buildings constructed along this portion of San Antonio Road. In 1953, the year the subject building was completed, the city directory for Palo Alto listed only one address, a road construction company, on San Antonio Road. The road is described as running “south from Bay Shore hway, 1 e of Diss rd.”14 The 1954 Polk’s city directory lists addresses on San Antonio between 126 and 996, stretching from the Bayshore Highway to the block south of Leghorn Street, but does not include the subject property.15 The earliest directory listing for the address was published in 1955.16 By the mid-1950s, the area between Charleston Road to the north and Middlefield Road to the south had changed drastically, with residential subdivisions and commercial thoroughfares taking the place of the open fields of only a decade earlier (Figure 16). 11 Ibid., 11-20. 12 Advertisement for Peninsula Garden Farms, San Francisco Examiner, September 10, 1926, 30 13 Advertisement for Peninsula Garden Farms, San Francisco Examiner, April 16, 1927, 16. 14 R.L. Polk & Co., Polk’s Palo Alto City Directory (San Francisco: R.L. Polk & Co, 1953), 636. 15 R.L. Polk & Co., Polk’s Palo Alto City Directory (San Francisco: R.L. Polk & Co, 1954), 836-837. 16 R.L. Polk & Co., Polk’s Palo Alto City Directory (San Francisco: R.L. Polk & Co, 1955), 265. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 78 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 13 - Figure 15. 1941 Aerial photograph of the project vicinity. Subject parcel outlined in orange. Source: Fairchild Aerial Surveys, Flight C-660, Frame 381, collection of the UC Santa Barbara Library. Edited by Page & Turnbull. Figure 16. 1956 Aerial photograph of the project vicinity. Subject parcel outlined in orange. Source: Aero Services Corporation, Flight CIV-1956, Frame 9r-33, collection of the UC Santa Barbara Library. Edited by Page & Turnbull. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 79 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 14 - JAPANESE AMERICAN FLORICULTURE IN THE SAN FRANCISCO BAY AREA Among the earliest economic contributions of Japanese immigrants to California was their employment as farm laborers, with large numbers arriving between the turn of the twentieth century and the passage of the Immigration Act, also known as the Japanese Exclusion Act, of 1924. In 1900, just over half of the state’s Japanese American population centered around the San Francisco Bay Area. Even while in following decades many families sought opportunities in other parts of the state, until World War II the Bay Area was home to nearly one-fifth of California’s Japanese American population.17 Japanese immigrants to California began growing flowers in the San Francisco Bay Area in the last decades of the nineteenth century, and many of those who began work in California as laborers later established their own family farms specializing in cut flower production or produce. It was in the Bay Area that the state’s Japanese American cut flower industry originated with growers such as the Domoto Brothers and Hiroshi Yoshiike. Yohnoshin and Kanetaro Domoto, from the Wakayama prefecture in Japan, began their nursery in Oakland around 1885. With brothers Motonoshin and Mitsunoshin, the Domotos bought two acres of land in Oakland in 1895 and soon employed a large workforce of Japanese-born laborers. 18 Hiroshi Yoshiike began producing chrysanthemums for sale in Oakland in 1886. By 1890, Yoshiike’s business success allowed him to buy an acre of land in Oakland and build five glass houses. Noritaka Yagasaki notes that early Japanese American growers were not formally trained in floriculture before starting their businesses in California. They learned, rather, from their own efforts and, in later years, by working for more experienced growers such as the Domoto brothers, whose business employed many laborers with roots in their home prefecture of Wakayama.19 For example, after working for the Domotos, brothers Eikichi and Sadukusu Enomoto purchased five acres in Redwood City to begin greenhouse cultivation of carnations and roses. Within a short time, Sadukusu Enomoto began growing chrysanthemums, which he sold wholesale at the Domoto brothers’ market on Lick Place, San Francisco.20 In the first decades of the industry’s growth, the Bay Area’s flower producers were located in two concentrations of activity: the East Bay, including Richmond, Berkeley, and Oakland; and the San Francisco Peninsula, with growers in the areas surrounding San Mateo, Belmont, Redwood City, and Mountain View. By the end of the first decade of the twentieth century, the East Bay had nearly three dozen Japanese American-owned nurseries, most specializing in chrysanthemums, carnations, and roses.21 Redwood City had become the early center of chrysanthemum growing in the region, with the city claiming itself in 1926 to be the Chrysanthemum Center of the World, boasting more than seven million dollars in annual income from the flowers’ sale.22 It is important to note that many of the growers in both the East Bay and Peninsula areas purchased land before the passage of the California Alien Land Law of 1913, which prohibited purchase or long-term lease by immigrants ineligible for citizenship in the United States. Yagasaki writes: 17 Noritaka Yagasaki, Ethnic Cooperativism and Immigrant Agriculture: A Study of Japanese Floriculture and Truck Farming in California. (Ph.D. Dissertation, Department of Geography, University of California, Berkeley, 1982), 35-36. 18 Ibid., 39. 19 Ibid., 43-44. 20 Gary Kawaguchi, Living With Flowers: The California Flower Market History. (San Francisco: California Flower Market, 1993) 33. 21 Yagasaki, Ethnic Cooperativism and Immigrant Agriculture, 46. 22 Jagruti Patel, Japanese Americans in Redwood City: A Local History (Master of Arts Thesis, Department of History, San Jose State University, 2004), 5. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 80 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 15 - Partly because of this high rate of land ownership from the beginning of their involvement, the flower growers of the Bay Area were not seriously affected by the Alien Land Law. Some of them had incorporated their nurseries before the land law took effect. I n any event, most of the growers had children born on American soil, who could acquire title to the land.23 The 1913 Alien Land Law was found unconstitutional in 1948, and was repealed in California in 1956. Japanese American growers who established their operations in the San Francisco Bay Area had connections to geographic and cooperative organizations with roots in Japanese rural organization that maintained a fundamentally feudal system of land tenure.24 Though late nineteenth-century rural cooperatives in Japan were different in role and structure from those instituted in the Americas, Japanese immigrants brought with them a spirit of rural cooperativism that took different forms from that maintained in Japan. First generation, or Issei, immigrants to the United States initially maintained connections to one another through prefectural associations, as well as fraternal and trade organizations. Agricultural cooperatives in California, referred to as Sangyo kumiai, supported collective approaches to credit, marketing, purchasing, and production of flowers or produce.25 Among the most influential organizations, which spurred the growth of California’s cut flower industry, were the California Flower Growers Association, founded in San Francisco in 1906 in the wake of the earthquake and fires, and the marketing cooperative, the California Flower Market, Inc., incorporated in 1912.26 The membership of the former were exclusively Issei growers.27 Later Japanese-operated flower growers’ organizations included the Carnation Growers Association (c. 1914), the Redwood City Nurserymen’s Association (1917), and the California Chrysanthemum Growers Association (1932).28 The early importance of the California Flower Market in the Japanese American floriculture industry cannot be overstated. It provided a central organization for selling growers’ products as well as sharing resources and information. Alongside market organizations dominated by Italian American and Chinese American growers, the California Flower Market’s 5th Street, and later Sixth and Brannan Street locations in San Francisco provided the main venues for Bay Area growers’ wholesale and retail sales.29 In the next section, the context for Japanese American floriculture in the San Francisco Bay Area from the 1930s onward focuses on the operation of the California Chrysanthemum Growers’ Association. Definitive histories of the California Flower Market, Inc. have been produced by Gary Kawaguchi, in his 1993 Living With Flowers and 1995 doctoral dissertation, Race, Ethnicity, Resistance and Cooperation: An Historical Analysis of Cooperation in the California Flower Market. An extensive discussion is also provided by Noritaka Yagasaki’s 1982 dissertation, Race, Ethnicity, Resistance and Cooperation: An Historical Analysis of Cooperation in the California Flower Market. In addition, The history of Japanese American social and economic activity in San Mateo and Santa Clara Counties is well documented by Gayle K. Yamada and Dianne Fukami’s Building a Community: the Story of Japanese Americans in San Mateo County, published by the Asian American Curriculum Project in 2003; the San Mateo Chapter of the Japanese American Citizens League’s 1872-1942: A Community Story, published in 1981; 23 Yagasaki, Ethnic Cooperativism and Immigrant Agriculture, 74. 24 Ibid., 4-5, 23-24, 29. 25 Ibid., 27. 26 Ibid., 35-36; Linda L. Ivey and Kevin W. Kaatz, Citizen Internees: A Second Look at Race and Citizenship in Japanese American Internment Camps (Santa Barbara, CA: Praeger, 2017), 47. 27 Yagasaki, Ethnic Cooperativism and Immigrant Agriculture, 49. 28 Ibid., 50-51. 29 Ibid., 51. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 81 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 16 - Timothy J. Lukes and Gary Y. Okihiro’s Japanese Legacy: Farming and Community Life in California's Santa Clara Valley, published in 1985 by the California History Center at De Anza College; and Dianne Fukami’s 1994 documentary film, Chrysanthemums and Salt, produced by KCSM-TV and the San Mateo Community College District. THE CALIFORNIA CHRYSANTHEMUM GROWERS ASSOCIATION As noted above, in the first decades of the twentieth century most of the Bay Area’s chrysanthemum growers were Japanese American families centered around the Redwood City and Belmont areas, with 40 of the Peninsula-based members of the California Flower Market producing Chrysanthemums by the late 1920s.30 After about 1904, the practice of shading Chrysanthemums under cheesecloth-covered frames led to a major shift in the Japanese American growers’ production capacity. While the mild climate of the San Francisco Peninsula was already ideal for growing chrysanthemums, commercial growers found that the cheesecloth shading could improve the quality and yield of their flowers.31 This innovation also created what became the familiar landscape of cheesecloth covered frames that dominated chrysanthemum nurseries until the 1930s. In the depression years of the early 1930s, individual growers on the Peninsula experienced difficulty securing payment on their orders from shippers, who were expected to collect payment from the flowers’ purchasers. Chrysanthemum growers faced the necessity of gaining better control of their shipping and credit to survive the financial hardship caused by reduced demand for and dropping price of their products.32 In response to these pressures, the California Chrysanthemum Growers Association (CCGA) was founded in Redwood City and formally incorporated on April 6, 1932, under director Toru Yamane and manager Joseph Iwasuke Rikimaru. With its membership entirely consisting of Japanese American growers, the organization was one of many ethnic cooperatives in northern California’s floriculture industry established in the early decades of the twentieth century.33 Rikimaru was experienced with growers' cooperative organizations at the time he started with the CCGA, having previously worked with the Livingston Fruit Growers Association.34 Rikimaru acted as a spokesperson for the CCGA’s members, and as a go-to for press inquiries regarding projected chrysanthemum supplies beginning in 1932. His experience with the Livingston Fruit Growers’ Association aided the CCGA’s success in regulating production and collecting debts owed to the members. 35 The first meeting of the CCGA was held on April 27, 1932 on the second floor of the Doxsee Building, located across Middlefield Road from the San Mateo County Courthouse in Redwood City.36 Noritaka Yagasaki’s 1982 dissertation provides the following thorough description of the CCGA’s founding and operations: It aimed at the adjustment of production acreage, improvement in marketing, control of market prices, and cooperative purchasing, when the industry was suffering difficulties. Consisting of Japanese chrysanthemum growers on the Peninsula, it had sections devoted to production, supply, collection and finance. By 1959 membership had reached 56. Plantings covered 90 acres and sales amounted to $300,000 annually. The association used the “tag system” to handle the sales of members’ chrysanthemums. Although buyers received flowers from each member grower, the purchase was made through the 30 Yagasaki, Ethnic Cooperativism and Immigrant Agriculture, 84-85. 31 Ibid. 32 Kawaguchi, Living With Flowers, 50-51. 33 Brian Niiya, Japanese American History: An A-to-Z Reference from 1868 to the Present. (New York, NY: The Japanese American National Museum, 1993). 34 Kawaguchi, Living With Flowers, 51. 35 “Early Cutting of Mums This Year,” San Mateo Times and Daily News Leader, July 22, 1932, 8. 36 California Chrysanthemum Growers Association, Kiku Kumiai, Fifty Years, edited by Hiroji Kariya (Palo Alto: 1981), 5. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 82 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 17 - association. Buyers received tags from growers to specify the volume and value of purchase, and the payment was made to the association. Members, in turn, received their sale proceeds from the association, and became free from bookkeeping obligations. This rationalization of the marketing process reduced conflict among growers and buyers. The association’s success in protecting the individual growers was beyond dispute.37 Most members’ flowers were initially sold at the California Flower Market in San Francisco, with many growers shipping via the Shima Transfer company of San Francisco.38 The association’s cooperative structure protected its grower members from price fluctuations and provided opportunities for marketing and distribution not available to individual growers. The organization took over collections on accounts, regulated production levels among members to control supply, and facilitated cooperative purchase of supplies to reduce growers’ costs. Buying in bulk, the association could sell supplies such as cheesecloth, waxed paper, pipes, twine, insecticides, and tools at lower prices than if growers purchased individually.39 With a cooperative approach to supply purchasing, members could adopt new growing techniques not as available to individual growers. CCGA members’ adoption of the use of shade cloth over their plantings beginning in 1933 allowed the usually short fall harvest – and growers’ months of productive income – to be lengthened. As covering their growing frames with cloth was a labor-intensive activity, each spring growers' families would gather to help each other with the task.40 The association placed a half-page advertisement in the October 7, 1936 issue of the San Mateo Times and Daily News Leader, introducing readers to the Japanese origin of the flower and announcing that “San Mateo County is the Large Chrysanthemum Center of the World.”(Figure 17)41 The CCGA initially included just over 40 members, and the Board of Directors initially included representatives from three districts: San Mateo-Belmont, Redwood City-Menlo Park, and Mountain View- Sunnyvale.42 In 1938, five Japanese families who had previously been leasing the Horgan Ranch property near Redwood City bought the property in their American-born children’s and cousins’ names – an arrangement necessitated by legal restrictions on land ownership for Japanese-born growers.43 The CCGA built an office and warehouse at the location in 1939. In 1942, the forced relocation of Japanese Americans under the Executive Order 9066 directly impacted the lives of the CCGA’s entire membership and created gaps in the supply of cut flowers to markets nationwide. Before the order was signed, Japanese Americans were arrested in raids in Peninsula counties aimed at detaining “Japanese, German, and Italian nationals and against axis nationals who had failed to turn in contraband radios, cameras, signaling devices, and weapons.”44 CCGA president Kotoharu Inouye was arrested by the FBI on December 8, 1941. His brother was among seven flower growers and nurserymen arrested in Redwood City in February 1942.45 37 Yagasaki, Ethnic Cooperativism and Immigrant Agriculture, 86-87. 38 CCGA, Kiku Kumiai, 5. 39 Ibid., 6. 40 Ibid., 7, 13 41 “Chrysanthemums,” San Mateo Times and Daily News Leader, October 7, 1936, 4. 42 CCGA, Kiku Kumiai, 4. 43 “Japanese Buy Horgan Ranch,” San Mateo Times and Daily News Leader, December 31, 1938; CCGA, Kiku Kumiai, 6; Patel, Japanese Americans in Redwood City, 17; Donna Graves, “Transforming a Hostile Environment: Japanese Immigrant Farmers in Metropolitan California,” in Food and the City: Histories of Culture and Cultivation. Dumbarton Oaks Colloquium on the History of Landscape Architecture XXXVI, 2015, 209. 44 “14 Japs Held in Local Raids,” San Mateo Times and Daily News Leader, February 21, 1942, 2. 45 Ibid. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 83 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 18 - Figure 17. Advertisement for the CCGA, San Mateo County Times and Daily News Leader, October 7, 1936, 4. In March 1942, facing evacuation and the inability to maintain their business activities, the CCGA Board granted power of attorney to act as agent and overseer of the organization’s interests to J. Elmer Morrish, vice president of the First National Bank in Redwood City.46 Morrish was an established banking professional in Redwood City at the time he helped the Japanese growers, and during their wartime internment assisted not only the CCGA organization, but also more than 20 Japanese American families with banking, taxes, and land management.47 Individual San Francisco Peninsula growers faced different situations upon their return from internment following the end of the war. Some had leased their property to other growers who had maintained the nurseries, while others’ vacant properties had been damaged by thieves and vandals.48 Due to their agreement with Morrish, following the end of World War II, the CCGA resumed operations and continued to support its members’ growing businesses.49 By 1947, Rikimaru was again advising event organizers and reporters regarding the availability of chrysanthemums for the following season.50 The association continued to set an example for other growers’ groups in the post-war years, and maintained a pattern of family-based nurseries when growing operations faced competition from larger corporate growers and imports.51 46 Ivey and Katz, Citizen Internees, 48. 47 Patel, Japanese Americans in Redwood City, 36. 48 CCGA, Kiku Kumiai, 8. 49 Ibid., 7. 50 “Fiesta Gets 9 Days’ Racing,” San Mateo Times, November 19, 1947, 1. 51 Kawaguchi, Living With Flowers, 64. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 84 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 19 - After the end of World War II, when many chrysanthemum growers returned to their San Mateo County farms, production of the flower resumed growth in the area. In the 1950s, Peninsula growers adopted the use of black cloth and artificial lighting to extend the blooming season of chrysanthemums, whose harvest had originally been limited to a short period in the fall.52 The proportion of greenhouse-grown chrysanthemums produced by San Mateo County growers increased as growers adopted the use of polyethylene-covered greenhouses, with indoor-grown area surpassing the outdoor-grown chrysanthemum area in 1967.53 Greenhouse growers could harvest three times each year, using steam sterilization and fungicides to prevent root diseases as they reused growing sites.54 During the last half of the twentieth century, growers could provide year round chrysanthemum production in greenhouses with artificial heat and cooling systems. The CCGA headquarters’ 1953 move from the Horgan Ranch property in Redwood City to 788 San Antonio Road, Palo Alto was spurred by broader postwar urban and suburban development throughout Peninsula cities that pushed growers’ territory southward. Prior to 1950, flower production in Santa Clara County had been far outweighed in importance by production in San Mateo and Alameda counties. By the 1960s, maintaining a nursery operation had become more expensive due to increased taxes and utility and labor costs. Redwood City growers struggled to compete with more economically produced imported South American cut flowers, and many nurseries shut down or left San Mateo County.55 Gary Kawaguchi writes: Agriculture has always yielded to the requirements of urban pressures. To paraphrase Yoshimi Shibata, roses like the same land that shopping malls grow on. Long-time growers sometimes found land becoming too valuable and yielded to pressures to sell out and move on. Some were forced out of their land in urban zoning battles.56 The CCGA’s 1981 history states that due to “urban encroachment spreading on the peninsula and the central point for members shifting south of Redwood City, growers began to consider relocating the Association office and warehouse to a lot on San Antonio Road in Palo Alto.”57 Palo Alto had previously been home to a modest concentration of Japanese American families. In 1942, as Japanese Americans faced relocation and internment, Palo Alto was home to less than 200 Japanese Americans, whose community centered around the two blocks of Ramona Street between Forest and Channing avenues.58 After the end of the war and their internment, the families who returned to Palo Alto rebuilt their businesses and religious communities away from their earlier Ramona Street enclave.59 This relatively small population was part of a much larger Japanese American population in the Santa Clara Valley, which had been working in agriculture in the area since shortly before the turn of the twentieth century. In the years between the 1890 and 1940 52 CCGA, Kiku Kumiai, 9. 53 Yagasaki, Ethnic Cooperativism and Immigrant Agriculture, 366-367, 375. 54 Kawaguchi, Living With Flowers, 72. 55 Patel, Japanese Americans in Redwood City, 51. 56 Kawaguchi, Living With Flowers, 73. 57 CCGA, Kiku Kumiai, 9. 58 Palo Alto Historical Association, "Palo Alto's Japanese-American Community," Supplement 1 to The Tall Tree, March 2017. 59 Sonia Dorfman, "The Japanese in Palo Alto," (May 1998) in Michael Corbett and Denise Bradley, Final Survey Report: Palo Alto Historical Survey Update, August 1997-August 2000 (San Francisco: Prepared by Dames & Moore for the City of Palo Alto Planning Division, 2001), 6-55. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 85 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 20 - censuses, the Japanese American population of the Santa Clara Valley increased from 27 individuals to 4,049.60 In 1953, the CCGA purchased the lot surrounding the subject property for $3,100, and began construction of their new headquarters. The total cost of the building was $19,842.77. By 1958, the association required additional space to serve its members’ production needs and expanded the rear of the building at a cost of $9333.21.61 In the years between 1954 and 1958, the number of carnation and chrysanthemum growers in Santa Clara County more than doubled. By 1966 concentrations of nurseries had grown in around Palo Alto, Mountain View, and San Jose.62 Growth in the county’s cut flower production continued to increase, and as of 1980 the estimated $28.8 million in flower production was dominated by $20.8 million in chrysanthemums.63 Many growers moved even further in the post-war years, establishing operations in Half Moon Bay, Pescadero, Gilroy, Watsonville, and Salinas.64 In 1957, 50 acres at the Horgan Ranch property was approved by the San Mateo County Board of Supervisors for zoning designation as a “floricultural zone” with the goal to “recognize and maintain the important contribution that floriculture is making to the economic welfare of the county.”65 While the property was no longer the headquarters of the CCGA, this designation protected some members’ production of chrysanthemums and carnations for a time. Development of the Horgan Ranch property in Redwood City as a residential suburb was approved in May 1983. Shortly after purchasing the corner lot encompassing the subject building, the organization purchased the adjoining lot to the north for $3400.00. 66 The CCGA built the commercial and warehouse building at 796 San Antonio Road, intended to be used partly for their own storage needs as well as rented to tenant businesses, in 1967. Continuing to operate at its San Antonio Road Headquarters, the CCGA became a stock company in 1973 and amended its by-laws to extend membership to flower growers whose primary focus was not chrysanthemums.67 In 1981, authors of the organization’s history wrote of the building, which was a focal point for professional development and social cohesion among the Japanese American flower growers’ community (Figure 18): The Association office has become a gathering place where growers, stopping to pick up supplies or to bring in their sales tags for collection, meet with other growers. There they exchange information on various aspects of business to keep abreast of the newest developments and keep up with the latest fishing news and golf scores.68 In a 1982 dissertation focused on Japanese American cooperative growers in California, Noritaka Yagasaki observed a general shift in the post-war years toward individualism among San Francisco Bay Area growers – with the exception of the chrysanthemum growers. He writes: Chrysanthemum growers on the Peninsula represent something of a special case, an exception to this trend [toward individualism]. The California Chrysanthemum Growers 60 Ibid., 6-51. 61 CCGA, Kiku Kumiai, Fifty Years, 10. 62 Yagasaki, Ethnic Cooperativism and Immigrant Agriculture, 372. 63 Ibid., 369. 64 Kawaguchi, Living With Flowers, 73. 65 “Horgan Ranch Flower Zoning is a Landmark,” San Mateo Times, October 18, 1957. 66 CCGA, Kiku Kumiai, Fifty Years, 10. 67 Ibid. 68 Ibid.,13. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 86 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 21 - Association established in 1931 by Japanese producers has played a central role in the development of chrysanthemum production on the Peninsula. The fiftieth anniversary was celebrated in 1981 with the publication of the history of the association. Half a century after its establishment, it continues to function as a growers cooperative. As of 1981, its 51 members were all Japanese. The contemporary grower members are located in Redwood City, the Palo Alto-Mountain View-Sunnyvale area, and in San Jose. Cooperative marketing of chrysanthemums is still carried out, while it also serves a fraternal function. There is a smaller Chinese chrysanthemum Growers Association, but it plays a much less important role both in supply and marketing. Locational cohesiveness of the members and the fact that they grow mainly chrysanthemums are the key factors of this long-lived ethnic organization of Japanese chrysanthemum growers. It, however, is gradually losing grower-members.69 When the CCGA’s historical narrative was produced in 1981, the Association maintained close ties with the California Flower Market in San Francisco, sent members to training courses on new techniques and to represent the Association at industry-related policy meetings, and communicated with the University of California Floriculture Research Station in San Jose regarding development of solutions to ongoing growing challenges.70 The CCGA’s primary office address was at 788 San Antonio Road until the at least the 1990s. The organization merged by 2002 with the California Flower Market, based at 640 Brannan Street, San Francisco.71 69 Yagasaki, Ethnic Cooperativism and Immigrant Agriculture, 384-386. 70 CCGA, Kiku Kumiai, 12. 71 United States Securities and Exchange Commission Form D, notification regarding “Common stock of California Flower Market, Inc. pursuant to merger agreement with California Chrysanthemum Growers Association Inc.,” February 20, 2002. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 87 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 22 - Figure 18. 1981 photograph of the CCGA “Anniversary Committee and History Project Committee” outside the headquarters at 788 San Antonio Road. Left to right: Jim Nakano, Ken Yamane, Richard Tsukushi, Shozo Mayeda, Hiroji Kariya, Sachi E. Adachi, Kio Yamane, George Nakano, and Richard Kaneko. Source: CCGA, Kiku Kumaiai, Fifty Years, 38. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 88 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 23 - V. SITE HISTORY SITE DEVELOPMENT 788 San Antonio Road was constructed in 1953 for the CCGA by Mountain View-based building contractor, Don Gordon (Figure 19). At the time of construction, 788 San Antonio Road had two 10-foot by 10-foot overhead doors, six three-foot by six-foot steel sash windows, and four four-foot by four-foot steel sash windows. The 50-foot wide building was originally 72 feet deep, and a rear 52- foot addition, with a third utility door on the south façade, was built in 1958. A 1965 aerial photograph shows the building with its current configuration, including the original front gabled portion and the 1958 rear warehouse extension (Figure 20). Figure 19. 1953 Photograph of the CCGA building at 788 San Antonio Road, shortly after completion. Source: Kariya, Kiko Kumaiai, Fifty Years, 10. Figure 20. 1965 aerial photograph of the project vicinity, subject property outlined in orange. Source: Cartwright Aerial Surveys, Flight CAS-65-130, Frame 4-184, edited by Page & Turnbull. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 89 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 24 - Construction Chronology The following table provides a timeline of construction activity at 788 San Antonio Road, based on building permit applications and assessment records on file with Palo Alto Development Services. The most visible changes recorded in this permit history include the 1974 replacement of the original front door with the current anodized aluminum-frame door and sidelight with tinted glazing, and the 2013 reroofing which replaced wood shakes with composition shingle roofing. Table 1. Building Permits on File for 788 San Antonio Road, Palo Alto Date Application # Owner/ Applicant Architect / Contractor Work 07/06/1953 10282 CCGA Don Gordon Construction of concrete block commercial building with cement floors, tar & gravel roof, sheet rock ceilings and interior partitions, and steel frame sash windows ($17,000) 02/21/1958 17006 CCGA Not listed Addition at rear ($5,000) 08/23/1967 0022753 Fred Hoshi Allsberry Plumbing Water heater installation 03/26/1974 A32995 CCGA Durnos Schroder AIA (architect); Ira Ota (builder) Interior alterations to form offices, completed 12/02/1974. 04/22/1974 C16627 CCGA Biber Electric Change of service, panel boards and switchboards. 04/16/1974 P2755 CCGA Dale Plumbing Gas outlet installation. 04/17/1974 H1499 CCGA Marelich Mechanical Co. Boiler installation 05/02/1974 Not listed CCGA West Coast Glass Co. Installation of bronze anodized aluminum door with bronze plate glass and sidelight with mail slot. 04/23/2003 03-ARB-31 CCGA Acquisition Corp. Design by Habitec Architecture and Planning Sign review and approval for new occupant, Mechanica Automotive. 12/22/2003 03-2965 CCGA Vance Brown, Inc. Tenant improvements for “Mechanica Automotive,” including installation of three car lifts within central repair portion of building (original 50- foot by 54-foot rear area). ($9,500) 10/26/2005 05-2990 CCGA Central Coating Co., Inc. Roofing: Sweep gravel, install sprayed polyurethane foam. ($22,438) 10/30/2013 13-2908 CCGA Above All Roofing Reroof: On front sloped portion of roof only, tear off existing shake, install new sheathing and comp shingles, approximately 14 squares. ($4,500) Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 90 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 25 - OWNERSHIP AND OCCUPANT HISTORY Through the majority of the years since its construction, the building at 788 San Antonio road was owned and used by the CCGA. In 2003, use of the building transferred to Mechanica Automotive Services, which operated at the location until 2018. The following table details the available ownership and occupancy history for 788 San Antonio Road is based upon city directory listings and building permit applications.72 Table 2. Owner and Occupant Chronology for 788 San Antonio Road, Palo Alto Year(s) Business Owner 1955-67 CCGA, Inc. Manager Joseph I. Rikimaru. CCGA 1968-1980 CCGA, Inc., Manager Hero Tsukuski CCGA 2003-present Mechanica Auto Services CCGA Acquisition Corp. 72 It should be noted that directories were not published in / are not available for all years. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 91 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 26 - VI. EVALUATION CALIFORNIA REGISTER OF HISTORICAL RESOURCES The California Register of Historical Resources (California Register) is an inventory of significant architectural, archaeological, and historical resources in the State of California. Resources can be listed in the California Register through a number of methods. State Historical Landmarks and National Register-listed properties are automatically listed in the California Register. Properties can also be nominated to the California Register by local governments, private organizations, or citizens. The evaluative criteria used by the California Register for determining eligibility are closely based on those developed by the National Park Service for the National Register of Historic Places. In order for a property to be eligible for listing in the California Register, it must be found significant under one or more of the following criteria. ▪ Criterion 1 (Events): Resources that are associated with events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States. ▪ Criterion 2 (Persons): Resources that are associated with the lives of persons important to local, California, or national history. ▪ Criterion 3 (Architecture): Resources that embody the distinctive characteristics of a type, period, region, or method of construction, or represent the work of a master, or possess high artistic values. ▪ Criterion 4 (Information Potential): Resources or sites that have yielded or have the potential to yield information important to the prehistory or history of the local area, California, or the nation. The following section examines the eligibility of 788 San Antonio Road for individual listing in the California Register: Criterion 1 (Events) 788 San Antonio Road appears to be individually eligible for listing in the California Register under Criterion 1 (Events) for its association with the California Chrysanthemum Growers Association, a long-term representative of the importance of Japanese American floriculture and industrial cooperatives in the San Francisco Bay Area. This cooperative floriculture group provided Japanese American growers on the San Francisco Peninsula with shared access to growing technologies, shipping options, and stabilized markets from its founding in 1932 to the end of the twentieth century. Though 788 San Antonio Road was not the first headquarters of the organization, it served as the longest center of operations for the CCGA and stands as a testament to the group’s ability to rebuild their businesses following the disruption of Japanese American internment during World War II. While the economic and social damages caused by internment challenged Japanese American growers, by maintaining strong business relationships among themselves and with non-Japanese banker J. Elmer Morrish, CCGA members were able not only to rebuild their businesses in the post- war years, but to expand production in response to technological change and market forces. The building at 788 San Antonio Road represents a different and significant segment of this resilient floriculture industry than that conveyed in previously evaluated floriculture sites in the San Francisco Bay Area. For example, the Sakai Nursery in Richmond, found eligible in 2004 for the National Register, represents a Japanese American family nursery which operated between 1906 and 2003, Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 92 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 27 - specializing in the production of greenhouse-grown cut flowers.73 In a 2018 Historic Resource Evaluation, Architectural Resources Group found the University Mound Nursery, located in San Francisco’s Portola district and founded by the Italian American Garibaldi family, to be eligible for the California Register under Criterion 1 for its association with the agricultural settlement of the neighborhood and Italian American community, and Criterion 3 as a “rare vernacular cultural landscape” representing a family-owned commercial nursery. Its period of significance was recommended to be 1921-1990, the years of operation under the Garibaldi family.74 Though not a Japanese American owned nursery, the University Mount Nursery is a significant reminder of the family-based Italian, Japanese, and Chinese nurseries that dominated San Francisco Bay Area floriculture, and one of a very few remaining Bay Area historic sites linked to the industry. In contrast to the significant, family-owned nurseries represented by these examples, the CCGA building at 788 San Antonio Road represents a cooperative organization that successfully facilitated the operation of numerous family nurseries on the San Francisco Peninsula for seven decades, and linked those nurseries to the wholesale and retail markets that supported their operation. It is a reminder that the floriculture industry did not just grow at nurseries, but relied on networks of relationships and locations that worked in concert. The front office accommodated the work of the organization in assisting family growers with their business operations, the rear warehouse space provided a storage and distribution point for the supplies purchased in bulk for use by member nurseries, and its location near the border between Palo Alto and Mountain View was chosen in direct response to the shifting post-war locations of its member nurseries. The organization’s second office and warehouse, built in 1939 at Horgan Ranch in Redwood City and used by the organization between 1939 and 1952, was also important. This location was directly connected to the group’s response to anti-Japanese land ownership laws and the effects of internment during World War II, while the extant, later building at 788 San Antonio Road represents the sustained relevance of the organization in the post-war years. Had the Horgan Ranch buildings been preserved, rather than demolished in the early 1980s to make way for suburban residential development, they may have been considered significant alongside the CCGA building on San Antonio Road as important markers of Japanese American growers’ cooperatives. Unfortunately, nothing appears to remain of the CCGA members’ work at Horgan Ranch. The period of significance of 788 San Antonio Road under Criterion 1 is 1953-2002, beginning with construction of the building and ending with the merger of the CCGA with the California Flower Market. Criterion 2 (Persons) 788 San Antonio Road does not appear to be individually eligible for listing in the California Register under Criterion 2 (Persons). While individuals associated with the CCGA during the group’s use of the building between 1953 and 2003, such as the organization’s first manager Joseph I. Rikimaru, were important in the local development of the floriculture businesses and professional organizations, the significance of the subject property is more appropriately connected to the work of the larger group rather than the contribution of individual members. 73 Donna Graves, Ward Hill, and Woodruff Minor; Historic Architecture Evaluation, The Oishi, Sakai, and Maida-Endo Nurseries, Richmond, CA (Prepared for Eden Housing, Inc., 2004); Department of Parks and Recreation 523 Forms for the Sakai Nursery (San Francisco, 2004); Historic American Landscapes Survey documentation for the Sakai Nursery, Greenhouses (HALS CA-6- B), https://www.loc.gov/pictures/item/ca3547/. 74 Architectural Resources Group, Historic Resource Evaluation: 770 Woolsey Street, San Francisco (Draft) (San Francisco: Prepared for 140 Partners LP, 2018). Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 93 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 28 - Criterion 3 (Architecture) 788 San Antonio Road does not appear to be individually eligible under Criterion 3 (Architecture), as a building that embodies the distinct characteristics of a type, period, region, or method of construction. Built in a vernacular utilitarian style, using functional materials selected to serve the needs of an organizational office and warehouse space, the appearance and configuration of the building is tied to its significance under Criterion 1. While the CCGA building exhibits a collection of features which generally convey mid-twentieth-century commercial use, it lacks the stylistic elements commonly associated with popular mid-century modern buildings. Its style is not representative of a significant type at the local, state, or national level, was not designed by a master architect or building professional, and lacks high artistic value. Research did not provide any evidence that building contractor Don Gordon was an important or influential building professional at the local, state, or national level. Criterion 4 (Information Potential) 788 San Antonio Road does not appear to be individually eligible under Criterion 4 as a building that has the potential to provide information important to the prehistory or history of the City of Palo Alto, state, or nation. It does not feature construction or material types, or embody engineering practices that would, with additional study, provide important information. Page & Turnbull’s evaluation of this property was limited to age-eligible resources above ground and did not involve survey or evaluation of the subject property for the purposes of archaeological information. CHARACTER-DEFINING FEATURES For a property to be eligible for national or state designation under criteria related to type, period, or method of construction, the essential physical features (or character-defining features) that enable the property to convey its historic identity must be evident. These distinctive character -defining features are the physical traits that commonly recur in property types and/or architectural styles. To be eligible, a property must clearly contain enough of those characteristics to be considered a true representative of a particular type, period, or method of construction, and these features must also retain a sufficient degree of integrity. Characteristics can be expressed in terms such as form, proportion, structure, plan, style, or materials. The character-defining features of 788 San Antonio Road include the following features original to its 1953 construction: • Rectangular, one-story massing, including original building and 1958 eastern extension; • Side- and cross-gabled roof element at west building façade; • Concrete masonry unit construction; • Multi-light steel-frame windows on north, west, and south façades; • Vehicle utility openings on south façade; • Wood-plank shelves below windows on west façade. INTEGRITY In order to qualify for listing in any local, state, or national historic register, a property or landscape must possess significance under at least one evaluative criterion as described above and retain integrity. Integrity is defined by the California Office of Historic Preservation as “the authenticity of an historical resource’s physical identity by the survival of certain characteristics that existing during Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 94 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 29 - the resource’s period of significance,” or more simply defined as “the ability of a property to convey its significance.”75 There are established integrity standards outlined by the National Register Bulletin: How to Apply the National Register Criteria for Evaluation. Seven variables, or aspects, that define integrity are used to evaluate a resource’s integrity—location, setting, design, materials, workmanship, feeling, and association. A property must stand up under most or all of these aspects in order to retain overall integrity. If a property does not retain integrity, it can no longer convey its significance and is therefore not eligible for listing in local, state, or national registers. The seven aspects that define integrity are defined as follows: Location is the place where the historic property was constructed. Setting addresses the physical environment of the historic property inclusive of the landscape and spatial relationships of the building(s). Design is the combination of elements that create the form, plans, space, structure, and style of the property. Materials refer to the physical elements that were combined or deposited during a particular period of time and in a particular pattern of configuration to form the historic property. Workmanship is the physical evidence of the crafts of a particular culture or people during any given period in history. Feeling is the property’s expression of the aesthetic or historic sense of a particular period of time. Association is the direct link between an important historic event or person and a historic property. Location 788 San Antonio Road retains integrity of location. The subject building has remained situated at its location of original construction since 1953. Setting 788 San Antonio Road substantially retains integrity of setting. The surrounding portion of San Antonio Road at the southeastern extent of Palo Alto was developed relatively quickly beginning in the early 1950s, and although the location was much less densely populated at the time the CCGA constructed the subject property, the overall setting, which consists of one-story service buildings accessed primarily by automobile with on-site parking areas, has remained much the same throughout the building’s use. Design 788 San Antonio Road retains integrity of design. The subject property has undergone only minor exterior alterations since the 1958 rear warehouse extension, built for use by the CCGA only five years after the building’s initial construction. Its composition, consisting of a front office segment for the daily business operations of the CCGA and rear warehouse space originally used for storage and distribution of growing supplies and equipment, has been retained. 75 California Office of Historic Preservation, Technical Assistance Series No. 7: How to Nominate a Resource to the California Register of Historical Resources (Sacramento: California Office of State Publishing, September 4, 2001), 11. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 95 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 30 - Materials 788 San Antonio Road substantially retains integrity of materials. The subject property has undergone minimal alterations since its original construction in 1953. The main entrance door was replaced in 1978 with a non-contributing tinted glass and anodized aluminum door. The wood-shake roofing was replaced with compatible composition shingles in 2013. The roll-up utility doors within the original openings on the south façade were replaced at an unknown time. These minor alterations do not detract from the overall character or design of the building, and all other character-defining features appear to retain their original materials. Workmanship 788 San Antonio Road retains integrity of workmanship. Many of the material choices and design elements are characteristic of mid-twentieth-century small-scale commercial buildings. For example, the concrete masonry unit construction, multi-light steel-frame windows, and flat or shallow-arched warehouse roof convey the goals of fairly utilitarian construction for the occupants’ commercial needs. The gabled roof portion at the west façade, though re-clad with modern shingles, adds interest to the most publicly visible portion of the building. Feeling 788 San Antonio Road retains integrity of feeling. The property was originally designed for use by a commercial organization, and has continued to function until very recently in a commercial service capacity. The property’s location, design, materials, and workmanship have been retained such that the building retains the overall feeling of a mid-twentieth-century suburban business. Association 788 San Antonio Road retains integrity of association. Due to the fact that the property retains integrity of location, design, materials, workmanship, and feeling, the property is clearly identifiable as the building constructed in 1953 by the CCGA. It retains sufficient integrity to convey its association with this organization and its contribution to Japanese American flower growers on the San Francisco Peninsula. Therefore, 788 San Antonio Road retains integrity to the degree necessary to appear eligible for individual listing in the California Register under Criterion 1 (Events) with a period of significance of 1953-2002. VII. CONCLUSION 788 San Antonio Road does appear to qualify for individual listing in the California Register of Historical Resources. The subject property is associated with the long-term operation of the California Chrysanthemum Growers Association, a Japanese flower growers’ cooperative that commissioned construction of the building in 1953. It therefore appears to be eligible for the California Register under Criterion 1. The subject property does not appear to be directly associated with the lives of any persons known to be significant and, therefore, is not eligible for listing in the California Register under Criterion 2. The building, constructed in 1953 by builder Don Gordon is a simple example of mid-twentieth-century commercial design with few stylistic features. It lacks the architectural or artistic value necessary for California Register eligibility under Criterion 3, or use of building or engineering techniques with information potential under Criterion 4. Therefore, 788 San Antonio Road does appear to qualify as a historic resource for the purposes of CEQA review. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 96 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 31 - VIII. REFERENCES CITED Published Works Architectural Resources Group. Draft Historic Resource Evaluation: 770 Woolsey Street, San Francisco. San Francisco: Prepared for 140 Partners LP, 2018. California Chrysanthemum Growers Association. Kiku Kumiai, Fifty Years, edited by Hiroji Kariya. Palo Alto: 1981. California Office of Historic Preservation. Technical Assistant Bulletin No. 8: User’s Guide to the California Historical Resource Status Codes & Historic Resources Inventory Directory. Sacramento: California Office of State Publishing. November 2004. Electronic document at http://ohp.parks.ca.gov/pages/1069/files/tab8.pdf, accessed March 11, 2019. _____. Technical Assistance Series No. 7: How to Nominate a Resource to the California Register of Historical Resources. Sacramento: California Office of State Publishing, September 4, 2001. Corbett, Michael and Denise Bradley. Final Survey Report – Palo Alto Historical Survey Update: August 1997-August 2000. San Francisco: Prepared by Dames & Moore for the Palo Alto Planning Division, 2001. Dorfman, Sonia. “The Japanese in Palo Alto” (May 1998), in Michael Corbett and Denise Bradley, Final Survey Report – Palo Alto Historical Survey Update, August 1997-2000. San Francisco: Prepared by Dames & Moore for the Palo Alto Planning Division, 2001. Graves, Donna. “Transforming a Hostile Environment: Japanese Immigrant Farmers in Metropolitan California,” in Food and the City: Histories of Culture and Cultivation. Dumbarton Oaks Colloquium on the History of Landscape Architecture XXXVI, 2015. Graves, Donna, Ward Hill, and Woodruff Minor. Historic Architecture Evaluation, The Oishi, Sakai, and Maida-Endo Nurseries, Richmond, CA. San Francisco: Prepared for Eden Housing, Inc., 2004. _____. Department of Parks and Recreation 523 Forms for the Sakai Nursery. San Francisco, 2004. Historic American Landscapes Survey. Documentation for the Sakai Nursery, 99 South 47th Street, Richmond, Contra Costa County, CA (HALS CA-6-B), https://www.loc.gov/pictures/item/ca3547/. Ivey, Linda L. and Kevin W. Kaatz, Citizen Internees: A Second Look at Race and Citizenship in Japanese American Internment Camps. Santa Barbara, CA: Praeger, 2017. Kawaguchi, Gary. Living With Flowers: The California Flower Market History. San Francisco: California Flower Market, 1993. National Park Service. National Register Bulletin Number 15: How to Apply the National Register Criteria for Evaluation. Washington, D.C.: National Park Service, 1997. Niiya, Brian. Japanese American History: An A-to-Z Reference from 1868 to the Present. New York, NY: The Japanese American National Museum, 1993. Palo Alto Historical Association. “Palo Alto’s Japanese-American Community.” Supplement 1 to The Tall Tree, March 2017. Patel, Jagruti. Japanese Americans in Redwood City: A Local History. Master of Arts Thesis, Department of History, San Jose State University, 2004. Winslow, Ward and Palo Alto Historical Association. Palo Alto: A Centennial History. Palo Alto, CA: Palo Alto Historical Association, 1993. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 97 Historic Resource Evaluation 788 San Antonio Road [16252H] Palo Alto, California June 5, 2020 Page & Turnbull - 32 - Yagasaki, Noritaka. Ethnic Cooperativism and Immigrant Agriculture: A Study of Japanese Floriculture and Truck Farming in California. Ph.D. Dissertation, Department of Geography, University of California, Berkeley, 1982. Public Records Building Permit Applications. Palo Alto Development Services. California Historical Resource Information System (CHRIS), Historic Property Data File for Santa Clara County, March 4, 2012. City of Palo Alto. Comprehensive Plan 2030. Adopted by City Council, November 13, 2017. Electronic document at https://www.cityofpaloalto.org/civicax/filebank/documents/62915, accessed January 2, 2019. –––––. City of Palo Alto, Master List of Structures on the Historic Inventory, July 24, 2012. Electronic document at https://www.cityofpaloalto.org/civicax/filebank/documents/3504, accessed February 15, 2019. City of Palo Alto. Online Parcel Reports. Newspapers and Periodicals San Francisco Examiner San Mateo Times and Daily News Leader Archival Records Building Permit Record Index, Palo Alto Historical Association. University of California, Santa Barbara Library, Special Research Collections. Aerial Photography FrameFinder. https://www.library.ucsb.edu/src/airphotos/aerial-photography-information. R.L. Polk & Co. Palo Alto City Directories (1953-1980), via Ancestry.com. Internet Sources David Rumsey Historic Map Collection. “Depression, War, and the Population Boom.” Palo Alto Medical Foundation - Sutter Health. Accessed January 2, 2019. http://www.pamf.org/about/pamfhistory/depression.html. Google Maps. 2019. Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 98 417 S. Hill Street, Suite 211 Los Angeles, California 90013 213.221.1200 / 213.221.1209 fax 2401 C Street, Suite B Sacramento, California 95816 916.930.9903 / 916.930.9904 fax 170 Maiden Lane, 5th Floor San Francisco, CA 94108 415.362.5154 / 415.362.5560 fax ARCHITECTURE PLANNING & RESEARCH PRESERVATION TECHNOLOGY www.page-turnbull.com Item 3 Attachment D - Historic Resources Evaluation Packet Pg. 99 www.nelsonnygaard.com M E M O R A N D U M To: Grubb Properties From: Nelson\Nygaard Team Date: January 13, 2026 Subject: 788 San Antonio Road - TDM Plan Update – Final Introduction This TDM Plan Update for 788 San Antonio Road is provided to justify a reduced supply of on-site parking compared to the City of Palo Alto’s requirements. This memo presents the results of a shared parking analysis for the proposed 788 San Antonio Road development (“the project”) along with a set of transportation demand management (TDM) strategies selected to reduce traffic impacts and minimize environmental impacts, while enabling the completed project to thrive as a vibrant and attractive place to shop, eat, live, and do business. It also summarizes the results of a parking demand analysis that factors for both the supply efficiencies expected from shared use of the project’s on-site parking, and the parking demand reduction impacts of the selected TDM strategies. Outline This memo summarizes the completed analysis and is organized as follows:  Proposed Land Use Program – the types and quantities/scale of uses proposed for the project  City Parking Requirements – minimum parking requirements for each use, based on City code  Proposed Parking Supply – the amount of on-site parking proposed for the project  Baseline Parking Demand Projections – initial estimates of peak parking demand for each use  Shared Parking Analysis – adjusted estimates of baseline peak parking demand, based on uses sharing the proposed on-site parking  TDM Analysis – parking demand impacts from TDM strategies anticipated to encourage non-driving travel modes among the project’s future residents, commercial tenants, and visitors, which are then factored into an updated shared parking analysis  Findings – a comparison of parking demand projections with the City’s requirements and the proposed on-site supply Proposed Land Use Program The development will include 167 residential units, comprised of 37 studio units, 96 one-bedroom units, and 34 two-bedroom units. 33 units will be rented at below-market rates for qualified households, satisfying a Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 100 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 2 20% requirement for affordable housing units for a Planned Housing Zone project. Approximately 1,500 square feet of ground-floor retail space is also proposed, to be located at the corner of San Antonio Road and Leghorn Street. City Parking Requirements Per the Palo Alto Municipal Code chapters 18.52 and 18.54, the proposed program requires 201 residential spaces. The Service Commercial (CS)-designated zone for the lot exempts parking requirements for the first 1,500 square feet of ground-floor retail. Under this exemption, 0 spaces will be required for retail use. Proposed Parking Supply The project is proposed to include 74 parking spaces, within a podium parking structure at grade and second floor of the building. The proposed parking supply is less than the City’s required minimum supply. Baseline Parking Demand Projections Initial projections of peak parking demand were calculated for the project, based on the proposed land uses, applying standard parking-generation rates for each use. Findings are summarized below. Figure 1 Peak Parking Demand for each Proposed Land Use – Baseline Estimates Without TDM Land Use ITE1 Parking Demand Rate Proposed Units Projected Peak Baseline Parking Demand Without TDM or Context Spaces Per Residential (1BR) 0.68 Dwelling Unit 133 91 Residential (2+ BR) 0.93 Dwelling Unit 34 32 Residential (Affordable) 0.65 Dwelling Unit 27 18 Commercial 2.79 1,000 Gross SF 1.5 5 All 146 Shared Parking Analysis From this baseline projection, shared supply efficiencies were modeled, based on patterns of peak and off- peak demand for the proposed uses during typical weekdays and weekends. When these patterns vary between multiple land uses, sharing a supply of parking can reduce the total number of spaces needed. To right-size the project’s on-site supply, therefore, we factored in the offsetting peak/off-peak demand patterns typical of the proposed land uses, using Nelson\Nygaard’s shared parking model. The charts below present a graphic summary of how the patterns projected for each use created accumulations of demand across a typical weekday and weekend day. 1 ITE = Institute for Transportation Engineers, the source of standard baseline parking generation estimates used in this analysis. Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 101 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 3 Figure 2 Shared Demand (without TDM) Across All Proposed Land Uses - Weekday As shown, the cumulative demand peaks at approximately 140 spaces, with the peak projected to occur during the nights, when residents have returned home and have their cars parked. The shared demand adjustments for uses does not have a significant impact on the peak baseline demand amount, because the non-residential land use is of modest scale and is expected to generate parking demand only during hours when residential parking demand is below peak. Similar patterns are seen over the weekends as shown below. Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 102 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 4 Figure 3 Shared Demand (Without TDM) Across All Proposed Land Uses - Weekend TDM Analysis A TDM program can encourage non-driving mode use among the project’s future residents, employees, and visitors, reducing the project’s trip and emissions impacts, and reducing the project’s parking needs. The strategies outlined below were selected based on the project’s location, mobility context, and proposed land use programming – as well as for their synergistic potential to amplify their collective effectiveness, compared to the sum of their individual impacts. Figure 4 Proposed TDM Strategies TDM Strategy Description Cost Implementation of a local Transportation Management Agency (TMA) Commuter Shuttle and Programs In coordination with local businesses, major employers and nearby housing communities, a funded TMA (e.g., Palo Alto TMA or MVgo) would provide commuter shuttle services from the site to the San Antonio Caltrain Station, among other supportive services. Other services offerings through the TMA, such as rideshare programs, can be explored. TBD Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 103 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 5 TDM Strategy Description Cost On-site Transportation Coordinator On-site property management staff will provide a welcome package for new tenants, distribute Go Passes and other memberships, and additional information. Minimal: This should be the property manager, ideally one offering skills in maintaining and promoting the benefits of a TDM Plan and coordinating with neighboring properties. Monitoring Program By annually monitoring the TDM and parking program, the owner/management can adjust the resulting strategies to meet requirements, parking ratio, mode split, etc. A TDM monitoring report will initially be submitted to the City two years after building occupancy and subsequently on an annual basis (18.52.050) Pre-Tax Deductions for Transit Employees are allowed to exclude their transit or vanpooling expenses (up to the maximum amount allowed by federal tax law) from taxable income. This would be required of any commercial tenant at 788 San Antonio regardless of the size or other transportation benefits provided by the specific employer. Covered employees will include all who work an average of at least 20 hours per week over the course of the most recent calendar month. Cost-neutral. Information Boards/Kiosks TDM information boards, kiosk, and hotline/online access to transportation information and coordinators. Included in construction costs. Bicycle Parking The project is proposing a total of 120 bicycle parking spaces for residential and community use, including 102 long-term (Class I) and 18 short-term (Class II) bicycle parking spaces, which significantly exceeds the City’s requirement. Hardware for bicycle parking is currently in the procurement stage. 5% of the bicycle parking spaces will be dedicated for cargo bikes. Estimate: $800 - $1,000 per one unit of 8-bike double-decker bike racks. Bicycle Resources and Amenities To encourage biking, additional resources and amenities, such as a Bicycle Repair Station will be provided to support convenient maintenance of personal bicycles. Additional information and resources will be provided via the Information Boards and Kiosks. Estimate: $1,150-$2,150 for a bike repair stand. Dedicated Micromobility Fleet The project is proposing a dedicated fleet of micromobility services (bike share, e-scooters, e-bikes Estimate based on 9 bikes: $10,855. Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 104 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 6 TDM Strategy Description Cost etc.) located on the premises of the private property/development made available for residents to use. A minimum of 9 bikes is suggested, reflective of approximately 5% of the number of residential units. Charging outlets will be provided near the dedicated micromobility station. Programs, such as ON Bike Share, provide a turnkey, automated bike share program that can be customized, owned and operated at a specific property (including bicycles with smart locks, docking racks, a rider app, administrative software, and a mechanic app). The bicycles can be customized with the logo and name of the building and bike components to match the color of the building logo. On Bike Share estimates the cost of the program is ~$40/per unit and recommends 1 bike per 30 units – with a minimum of 5 bikes (with room to expand). With a program including 9 bikes, we are assuming the cost per unit would increase to ~$65/per unit. Unbundling Parking Keeping the price of parking separate from the cost of rent helps to ensure that monthly expenses are more affordable for those who do not want to own a car, while placing a premium on those who want guaranteed parking in an environment where there are other mobility options. Based on a monthly fee within the range of $100 to $300 (depending on the number of parking spaces requested by a household and/or ease of access to the parking space). Cost-neutral. Promotional Programs Promotion and organization of events for the following programs: new tenant orientation packets on transportation alternatives; flyers, posters, brochures, and emails on commute alternatives; transportation fairs; Bike to Work Day, Spare the Air; Rideshare Week; Palo Alto TMA Programs2 (e.g. Clipper or Lyft benefits for employees working in commercial areas); and trip planning assistance routes and maps. Responsibility of the site wide TDM coordinator to administer programming. Car Share Through the Envoy car share program, or similar car share programs, seven spaces would be dedicated for on-site car share. Car sharing programs allow people to have on-demand access to a shared fleet of vehicles on an as-needed basis. Car sharing has been shown to significantly reduce vehicle ownership and vehicle miles traveled (VMT). Making these vehicles accessible to residents increases the vehicle availability for non- A subscription program like the Envoy car share program, would cost approximately $20 per hour paid by the user. For the property, cost will reflect the loss of resident parking fees. Depending 2 Palo Alto TMA has three programs for Downtown and California Avenue employees. Employees earning less than $70,000 are eligible for a free, monthly transit pass as well as subsidized Lyft shared ride trips. Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 105 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 7 TDM Strategy Description Cost car owners and reduces the need for households to own more than one vehicle. on the car sharing program that ultimately occupies the spaces, a minimum subsidy for the program may be required. Reduced Residential Parking The on-site parking supply will have 74 spaces, whereas the minimum municipal requirement is 201 spaces. Reducing parking supply from the municipal requirement to accurately reflect shared peak demand will eliminate excess spaces that will otherwise be unoccupied. Note: This is not a TDM program, but rather a contextual factor that affected demand estimates. Cost savings achieved through reduced capital, operations, and maintenance for parking. Passenger Pick- Up/Drop-Off (PU/DO) Area To support an effective TDM program, a clearly designated Passenger Pick-Up/Drop-Off area will be incorporated in the site plan and design. Cost-neutral. Pedestrian and Bicycle Network Improvements Grubb is supportive of providing a bicycle lane or multimodal path in proximity to the site. In working with the City of Palo Alto, Grubb will provide support and input in the development of enhanced pedestrian and bicycle improvements along San Antonio Rd., much of which is conditional on the continued development and implementation of the San Antonio Road Area Plan. TBD Transit Stop When VTA transit services are expanded further north along the San Antonio Rd corridor, Grubb will work with City to coordinate enhanced transit accessibility from their site. If a transit stop is suitable at or near the site, Grubb will work with the City to ensure the provision of a transit stop is well integrated within the property, and that the transit stop will include elements that provide a positive and safe user experience. To encourage transit use, physical upgrades at transit stops may include shelters, seating, increased pavement areas for standing/sitting, improved lighting, and clear signage and branding. · Benches: ~$3,000 · Signage ~$200 (non- digital) · Basic shelter: ~$100,000 Two or more land uses on site The impact of a mixed-use/shared-parking environment helps reduce parking supply needs by allowing multiple on-site land uses to be reached from a single parking space. This is often referred to as a “captive market” effect, where the trips made between uses without additional parking often referred to as an Cost-neutral. Local businesses and employees may help ensure revenue is also kept in proximity to the community. Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 106 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 8 TDM Strategy Description Cost “internal capture” rate. For example, a resident living above a café might walk downstairs to grab a coffee. Safe Routes to School Participation To support and encourage families to choose healthy, active, and sustainable alternatives to driving, the Safe Routes to School program offered by the City of Palo Alto will be promoted for participation among residents with school-aged children. Cost-neutral. Combined, this set of measures is projected to reduce baseline parking generation as follows:  Residents: 55.8%  Employees: 30.7%  Visitors: 10.7% The updated peak parking demand projections with TDM impacts are shown below, with weekday and weekend peak projections at 68 spaces. Adding seven spaces for the proposed car-share vehicles, this brings the total projected peak demand to 75 spaces. Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 107 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 9 Figure 5 Demand Across All Proposed Land Uses (with TDM) - Weekday Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 108 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 10 Figure 6 Demand Across All Proposed Land Uses (with TDM) - Weekend Findings Primary Finding: Parking Demand and Supply Our analysis identifies a peak on-site parking demand of 75 parking spaces for the proposed project, inclusive of the TDM program outlined above. Secondary Finding: Trip Generation & VMT Impacts The focus of this memo is to confirm the suitability of the proposed on-site parking supply for the project when factoring for its proposed TDM Plan. However, it is worth noting that the measures included in that plan will also significantly reduce the trip-generation and vehicle-miles-traveled (VMT) impacts of the project. Because the nature of the proposed property is predominantly residential, the parking demand reductions outlined above would result from reduced levels of resident car ownership – meaning that the parking demand reduction of 52% equates to 52% fewer vehicles owned by the project’s future residents. Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 109 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 11 While it is likely that this reduced level of vehicle ownership is likely to be skewed toward future residents who would have driven their vehicles less often and for fewer overall miles, reducing the number of resident vehicles by 52% will significantly reduce the trip and VMT impacts of the project – arguably by as much as half. At this level of vehicle access reduction among residents, the TDM Plan is projected to achieve a reduction in peak hour motor vehicle trips far in excess of the minimum 20%. Appendix: Reduction Factors for Proposed TDM Measures The tables below provide parking-demand reduction factors assigned by the NN model to each of the proposed TDM measures. To capture both synergistic and diminishing-return relationships among measures implemented as part of a comprehensive TDM Plan, the model categorizes potential TDM measures into functional categories. The model caps the cumulative impacts of measures within the same category – to reflect the diminishing returns expected from similar measures – ensuring that higher demand-reduction projections are only achievable through plans that include significant measures from multiple categories – incentivizing synergistic combinations of measures. As shown, several measures only have a secondary impact on parking demand – increasing the effectiveness of other, primary measures, with no direct reduction impact assigned. As more of these secondary measures are included, the model increases the total estimated effectiveness of the primary measures – those assigned a direct reduction estimate in the tables below. Figure 7 Parking Demand Reduction by Each TDM Measure Parking Policy and Pricing TDM Strategy Residents Employees Other Unbundling Parking 13.4% 12.0% N/A Reduced Residential Parking 38.5% Secondary N/A Passenger PU/DO Secondary Secondary Secondary Total 46.7%* 12.0% 0.0% *Category maximum capped at 35.0% Programs and Services TDM Strategy Residents Employees Other Car Share 15.0% 0.1% N/A Dedicated Micromobility Fleet 1.8% 1.8% 1.8% Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 110 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 12 Programs and Services TDM Strategy Residents Employees Other Funding of a local Transportation Management Agency (TMA) Commuter Shuttle and Programs Secondary 9.0% Secondary Pre-Tax Deductions for Transit Secondary Secondary N/A Safe Routes to School Participation Secondary Secondary N/A Total 21.3% 10.7%* 1.7% *Category maximum capped at 25.0% Physical Features TDM Strategy Residents Employees Other Two or more land uses on site 14.3% 1.8% Secondary Bicycle Parking 3.6% 3.5% 3.2% Pedestrian and Bicycle Network Improvements 2.0% 22.0% Secondary Transit Stop Secondary 6.7% 6.1% Bicycle Resources and Amenities Secondary Secondary N/A Total 19.0%* 13.3%* 9.1% *Category maximum capped at 10.0% Promotional Resources and Activities TDM Strategy Residents Employees Other On-site Transportation Coordinator 4.0% 2.0% N/A Monitoring program Secondary Secondary Secondary Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 111 788 San Antonio Road Grubb Properties Nelson\Nygaard Consulting Associates Inc. | 13 Promotional Resources and Activities TDM Strategy Residents Employees Other Information Boards/Kiosks Secondary Secondary Secondary Promotional Programs Secondary Secondary Secondary Total 4.0% 2.0% 0.0% TDM Category Residents Employees Other Parking Policy and Pricing 35.0% 12.0% 0.0% Programs and Services 21.3% 10.7% 1.7% Physical Features 10.0% 10.0% 9.1% Promotional Programs 4.0% 2.0% 0.0% Total 57.0% 41.8% 10.8% Item 3 Attachment E - TDM Plan and Parking Information Packet Pg. 112 Development Program Statement – 788 San Antonio Road (a) Necessity of the Planned Community (PC) District Application The proposed Planned Community (PC) District is necessary to enable a thoughtfully designed, higher-density mixed-use development that advances the City of Palo Alto’s adopted housing, sustainability, and transit-oriented development goals along the San Antonio Road corridor. The project replaces underutilized, low-intensity commercial uses with a vertically integrated multi-family residential development, optimizing land use efficiency in an accessible location with excellent proximity to jobs. Application of the PC District is required to allow: • Increased residential density to deliver 167 units, including 28 affordable units • Additional building height (approximately 84 feet) • Modified parking ratios reflecting a transit-oriented, multimodal context The proposed development is consistent with the required findings of Section 18.38.060 in that it: • Promotes orderly and efficient development of land in alignment with City policy direction • Provides superior site planning and design relative to conventional zoning standards • Advances housing production, including below-market-rate units • Enhances the public realm and pedestrian environment along a key corridor • Supports sustainability and reduced vehicle dependency through integrated transportation demand characteristics (b) Complete Listing of Proposed Uses The proposed PC District will allow the following uses, consistent with Palo Alto zoning terminology: Primary Uses • Multi-family residential (rental apartments) • Affordable housing units (Below Market Rate) Accessory Residential Uses • Residential amenities, including: o Co-working/lounge spaces o Fitness center o Rooftop clubroom and terrace o Pet spa o Outdoor courtyard and recreation areas Commercial Uses • Ground-floor retail (approximately 1,400 square feet), intended for: Item 3 Attachment F - Development Program Statement and Development Schedule Packet Pg. 113 o Neighborhood-serving retail o While this is included in the proposal, the viability of retail is questionable within the context of this building and corridor, currently under review in the San Antonio Road Area Plan Parking and Mobility Uses • Structured parking (two levels) • Bicycle parking and storage facilities (c) Description of Use Characteristics and Need for Modified Regulations The proposed development integrates residential in a compact, vertically mixed configuration that differs from conventional zoning assumptions in several key ways: Intensity and Built Form • Eight-story structure with increased height and density to support housing delivery goals • Reduced building massing through articulation, step-backs, and a courtyard design that greatly reduces the massing along San Antonio Road Parking and Transportation • Reduced parking supply (74 vehicle spaces for 167 units) supported by: o High bicycle parking ratio (167 spaces) o Proximity to transit and services o Evolving mobility patterns, reduced auto dependence and alternatives Operational Characteristics • Active ground-floor frontage along San Antonio Road with residential-focused activity Public Realm Enhancements • Pedestrian-oriented design with transparent frontages and active uses • Enhanced landscaping, lighting, and seating areas • Integration of open space and community-facing elements These characteristics warrant flexibility from standard zoning regulations to allow: • Increased height and density • Modified parking requirements • Refined massing and design standards Such modifications result in a higher-quality, policy-aligned development outcome than would be achievable under base zoning. (d) Housing Program Summary Unit Type Number of Units Studio 37 Item 3 Attachment F - Development Program Statement and Development Schedule Packet Pg. 114 Unit Type Number of Units One-Bedroom 96 Two-Bedroom 34 Total Units 167 • Affordable Units (BMR): 28 units • Housing Type: Market-rate rental apartments with integrated affordable housing Floor Area • Total building area includes residential, amenity, and approximately 1,400 square feet of retail space Pricing • Market-rate rents to be determined based on prevailing market conditions at time of lease-up • Affordable units to be priced in accordance with City of Palo Alto Below Market Rate (BMR) program requirements and Santa Clara County 51-80% AMI (e) Additional Information for Review Sustainability and Design • Energy-efficient building systems • Water-efficient, climate-appropriate landscaping • Pollinator-friendly plantings • Durable, high-quality exterior materials Site Redevelopment • Demolition of approximately 17,800 square feet of existing commercial buildings • Replacement with a higher-intensity, mixed-use development Consistency with Area Development Pattern • Aligns with emerging development trends along San Antonio Road • Comparable in scale and intensity to nearby GM-ROLM overlay criteria and recently proposed high-density residential projects in the vicinity • Reinforces corridor transformation into a transit-oriented, mixed-use district Item 3 Attachment F - Development Program Statement and Development Schedule Packet Pg. 115 Development Schedule – 788 San Antonio Road (a) Project Timeline Based on the applicant’s current understanding, the anticipated development timeline is as follows: • Entitlement Phase: Ongoing, with an estimated completion by late 2026 • Construction Documentation & Permitting: Preparation of construction drawings and securing of building permits anticipated to be completed by mid-2027 • Construction Commencement: Construction is expected to begin in the third quarter (Q3) of 2027 • Construction Duration: Approximately 30 months • Estimated Occupancy: Initial occupancy is anticipated in the first half of 2030, with full project completion occurring shortly thereafter This schedule reflects a continuous development process from entitlement through construction and occupancy. (b) Phasing Program The proposed development is planned as a single-phase project. Although the total development timeline exceeds two years, the project consists of one integrated mixed-use building and associated site improvements that will be constructed concurrently. As such, phased construction is neither necessary nor practical due to: • The unified structural design of the building • Integrated parking, residential, and retail components • Site-wide infrastructure and landscape improvements Accordingly, the development will proceed as one coordinated phase, with occupancy occurring upon substantial completion of the project. Item 3 Attachment F - Development Program Statement and Development Schedule Packet Pg. 116 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 Project Plans In order to reduce paper consumption, a limited number of hard copy project plans are provided to Commissioners for their review. The same plans are available to the public, at all hours of the day, via the following online resources. 1. Go to: bit.ly/PApendingprojects 2. Use the map to find “788 San Antonio” and click the green map icon link 3. On this project-specific webpage you will find a link to the project plans and other important information https://www.paloalto.gov/Departments/Planning-Development-Services/Current- Planning/Projects/788-San-Antonio-Rd-Zone-Change Item 3 Attachment G - Project Plans Packet Pg. 117 Item No. 4. Page 1 of 1 Planning & Transportation Commission Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: April 8, 2026 Report #: 2604-6198 TITLE Approval of Planning & Transportation Commission Draft Summary & Verbatim Minutes of February 25, 2026 RECOMMENDATION Staff recommends that the Planning & Transportation Commission (PTC) adopt the meeting minutes. BACKGROUND Draft summary and verbatim minutes for the February 25, 2026, Planning & Transportation Commission (PTC) meeting were made available to the Commissioners prior to the April 8, 2026, meeting date. The draft PTC minutes can be viewed on the City’s website at https://bit.ly/PaloAltoPTC ATTACHMENTS None AUTHOR/TITLE: Samuel Tavera, Administrative Associate III Item 4 Item 4 Staff Report Packet Pg. 118