HomeMy WebLinkAboutStaff Report 2603-6071CITY OF PALO ALTO
CITY COUNCIL
Special Meeting
Monday, April 13, 2026
Council Chambers & Hybrid
5:30 PM
Agenda Item
8.PUBLIC HEARING / QUASI-JUDICIAL. 3606 El Camino Real [24PLN-00162 & 25PLN-00243]:
Request for Approval of Applications for Major Architectural Review and Vesting Tentative
Map to Merge Seven Existing Parcels to Create a 113,907-Square-Foot Parcel and to
Construct a Seven-Story, Multi-Family Residential Housing Development Project with 321
Units, Thirteen Percent of Which Would be Provided at a Rate Affordable to Low Income.
The Project is Proposed in Accordance with Builder’s Remedy (California Government
Code Section 65589.5(d)(5)). A Senate Bill 330 Pre-Application was Filed on February 15,
2024. CEQA Status: Exempt Pursuant to Assembly Bill 130 (Public Resources Code Section
21080.66). Supplemental Report added, Staff Presentation, Applicant Presentation, Public
Comment
CITY COUNCIL
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: April 13, 2026
Report #: 2603-6071
TITLE
PUBLIC HEARING / QUASI-JUDICIAL. 3606 El Camino Real [24PLN-00162 & 25PLN-00243]:
Request for Approval of Applications for Major Architectural Review and Vesting Tentative Map
to Merge Seven Existing Parcels to Create a 113,907-Square-Foot Parcel and to Construct a
Seven-Story, Multi-Family Residential Housing Development Project with 321 Units, Thirteen
Percent of Which Would be Provided at a Rate Affordable to Low Income. The Project is
Proposed in Accordance with Builder’s Remedy (California Government Code Section
65589.5(d)(5)). A Senate Bill 330 Pre-Application was Filed on February 15, 2024. CEQA Status:
Exempt Pursuant to Assembly Bill 130 (Public Resources Code Section 21080.66).
RECOMMENDATION
Staff recommends that City Council:
1. Consider the project exempt from California Environmental Quality Act (CEQA) in
accordance with Assembly Bill (AB) 130 (Public Resources Code Section 21080.66); and
2. Approve the Major Architectural Review and Vesting Tentative Map applications based
on findings and subject to conditions of approval in the Draft Record of Land Use Action
(RLUA) in Attachment B.
EXECUTIVE SUMMARY
The proposed residential project includes 321 rental units, thirteen percent of which would be
provided at a rate affordable to low-income households or below, with two levels of above
ground parking.1 The project includes demolition of 38 residential units as well as
approximately 12,572 square feet of commercial floor area across seven existing parcels
located at 3508, 3516, 3606, and 3626-3632 El Camino Real, and unaddressed parcel on
Matadero Avenue, as well as 524-528 and 530 Kendall Avenue. These parcels are proposed to
1 Inclusionary percentage is based on the pre-density bonus count of 284 units.
be merged under a vesting tentative map to create a single parcel for the proposed
development.
BACKGROUND
Planning and Transportation Commission
On February 11, 2026, the PTC considered the Vesting Tentative Map and recommended denial
(3-2-1), with Chair Akin and Commissioner Hechtman dissenting, and Commissioner Peterson
abstaining. The Subdivision Map Act sets forth a series of reverse findings and requires denial if
any one finding can be made in the affirmative. The recommendation for denial was based on
the conclusion that Finding #6, which states: “..the design of the subdivision or type of
improvements is likely to cause serious public health problems” could be made in the
affirmative and therefore recommended denial. The PTC expressed that insufficient
information had been provided to show that the project would not cause a public safety
concerns for bicyclists and pedestrians along safe routes to school.
Project and cumulative traffic safety analysis;
Providing sidewalk easements;
Relocating ingress/egress to improve pedestrian and bicycle safety and reduce
congestion near El Camino Real intersections; and
Incorporating portions of the site for a bike path.
Specifically, the PTC was concerned that a traffic analysis had not yet been conducted for
the site and that cumulative impacts from proposed projects within the vicinity, particularly
a proposed project at 3400 El Camino Real, across Matadero Avenue, had not been
evaluated. The PTC encouraged relocating the vehicular access to the site from side streets
to avoid congestion on Matadero and Kendall Avenue, particularly on Matadero Avenue as
a safe-routes to school route. Multi-modal access, particularly in response to feedback from
public comment and the PTC is discussed further below in the analysis.
Architectural Review Board
On December 4, 2025, the ARB held an early hearing to provide feedback on the proposed
project design as summarized with the following key comments:
Building Massing/Façade Articulation: Board members encouraged additional
articulation, step-backs, and architectural detailing to reduce perceived bulk and
enhance visual interest.
Height Transitions: Board members encouraged stepping down the building, particularly
at the rear, to better transition to adjacent lower-scale development and reduce
impacts on neighboring properties.
Open Spaces and Amenity Design: Board members encouraged improvements in
usability and overall quality.
The applicant addressed most ARB comments and submitted a visual design updates document
outlining how the design responds to the feedback (Attachment F).
Project Description
The proposed project includes 321 residential rental units, thirteen percent of which would be
provided at a rate affordable to low-income households or below. This percentage is based on
the total number of units allowed prior to the application of state density bonus (284 units),
resulting in a total of 37 new affordable units. The building would include two levels of above-
grade parking, ground floor residential amenities, and a rooftop terrace facing El Camino Real.
The project includes demolition of the existing uses, including 38 residential rental units, none
of which are currently deed restricted, and approximately 12,572 square feet of commercial
floor area across seven existing parcels located at 3508, 3516, 3626-3632 El Camino Real, and
524, 528, 530 Kendall Avenue. These seven parcels would be merged under the tentative map
application to create a single 113,907-Square-Foot resulting parcel for the proposed
development (25PLN-00243). Attachment A includes a location map. Attachment F includes a
summary from the applicant asserting their legal rights and Attachment G includes the project
plans.
The applicant submitted a SB 330 pre-application on February 15, 2024 (24PLN-00047).
Therefore, the project analysis is based on the applicable standards at the time the compliant
SB 330 pre-application was submitted. The project is also being proposed in accordance with
California Government Code Section 65589.5(d)(5) (also known as Builder’s Remedy) and
qualifies for additional protections as a “Builder’s Remedy 2.0 project,” under AB 1893. The
applicant’s project description is provided in Attachment F and includes a list of waivers
requested in accordance with State Density Bonus Law. As detailed further in this report, if the
project is designed to comply with all relevant objective standards, after application of density
bonus incentives, concessions, and waivers, the City cannot impose conditions that would
preclude construction of the project as proposed.
Architectural Review – Major (AR): The process for evaluating this type of application is
set forth in Palo Alto Municipal Code (PAMC) Section 18.77.070. AR applications are
reviewed by the ARB and recommendations are forwarded to the Planning and
Development Services Director for action within five business days of the Board’s
recommendation. Action by the Director is appealable to the City Council if filed within
14 days of the decision. The Director may instead forward a project directly to City
Council for final action in accordance with PAMC Section 18.40.180. AR projects are
evaluated against specific findings. All findings must be made in the affirmative to
approve the project. Failure to make any one finding requires project redesign or denial.
The findings to approve an AR application are provided in Attachment B.
Vesting Tentative Map: The process for evaluating this type of application is set forth in
Title 21 of the PAMC and California Government Code 66474. The process for approval
of a Vesting Tentative Map for a condominium subdivision is outlined in PAMC Sections
21.12.010 and 21.13.020. Vesting Tentative Maps require PTC review. The PTC reviews
whether the amended subdivision is consistent with the Subdivision Map Act (in
particular, Government Code 66474, Title 21 of the PAMC, the Palo Alto Comprehensive
Plan, and other applicable provisions of the PAMC and State law. The PTC’s
recommendation is forwarded to the City Council for final approval. Findings for Council
to approve the Vesting Tentative Map are provided in Attachment B.
Housing Accountability Act (Government Code 65589.5): The project constitutes a
“housing development project,” as well as “housing for very low, low-, or moderate
income households” under the Housing Accountability Act. The Housing Accountability
Act Section 65589.5(d) states that a city cannot deny such a project or impose
conditions of approval that would render it infeasible unless it makes specified findings.
Among those findings are: that the project would have a specific, adverse impact upon
the public health or safety that cannot be mitigated. “Specific, adverse impact” means
“a significant, quantifiable, direct, and unavoidable impact, based on objective,
identified, written public health or safety standards, policies, or conditions as they
existed” at the time of the preliminary application.
Because the project is a “Builder’s Remedy 2.0 project,” under AB 1893, the City is
further limited to only enforcing those objective standards that exist in a zone district or
land use designation that allows the density requested. If there are no such zoning
districts or general plan designations in the City, then the applicant may identify any City
standards that facilitate the project and only those standards shall apply. If the project
meets these identified standards, the City cannot impose conditions of approval that
preclude the project from being constructed as proposed by the applicant.
Because the project is a “Builder’s Remedy 2.0 project,” under AB 1893, the “base
density” for purposes of State Density Bonus Law shall be the maximum density
permitted for Builder’s Remedy projects (e.g. three times the density permitted in the
zoning code or general plan). The project applicant is also able to utilize incentives,
concessions, and waivers under State Density Bonus Law when demonstrating
compliance with the enforceable standards.
ANALYSIS
Staff evaluated the project in accordance with the Comprehensive Plan, Zoning Ordinance, and
other applicable goals and policies of the City and found the project consistent or otherwise
deviates in a manner permissible under State law.
Consistency with the Comprehensive Plan, Area Plans, and Guidelines
The project site includes seven parcels with varying Comprehensive Plan land use designations,
including Service Commercial, Neighborhood Commercial, and Multiple-Family Residential
designations as reflected in Attachment A. Consistent with the Comprehensive Plan’s
encouragement of housing near transit centers, higher density multi-family housing may be
allowed in specific locations in the Service Commercial and Neighborhood Commercial land use
designations. The project is located along a high-quality transit corridor and the portions of the
project site that are within these land use designations are identified as Housing Inventory Sites
under the adopted Housing Element. Therefore, the proposed use multi-family residential use is
consistent with these Comprehensive Plan land use designations.
Other portions of the project site are designated multiple-family, where the permitted number
of housing units varies by area, depending on existing land use, proximity to major streets and
public transit, distance to shopping and environmental problems. Net densities range from 8 to
90 persons per acre (8 to 40 units). Density should be on the lower end of the scale next to
single-family residential areas. However, densities higher than what is permitted may be
allowed where measurable community benefits will be derived, services and facilities are
available, and the net effect will be consistent with the Comprehensive Plan.
While the density on the site exceeds the stated maximum of 40 units per acre set forth under
the land use designation, the proposed density is allowed pursuant to California Government
Code section 65589.5(h)(11)(C) as detailed further in Attachment D. Under these provisions the
base density allowed for the site as a whole is 108 dwelling units per acre (du/ac), which is
approximately 284 units for this site, plus a 24.5% bonus (70 units) based on the number and
income level of the below market rate units provided, resulting in a total of 335 units allowed
(density of approximately 136 du/ac). The project is providing a total of 321 units, which is
within the allowed density in accordance with the Builder’s Remedy provisions set forth in AB
1893.
Housing Element Consistency
Four of the seven parcels on which the proposed project would be located are identified as
housing inventory sites as detailed in the following table:
Address Capacity Income Levels
(Above Moderate Income)
(Above Moderate Income)
(Very Low Income); 6 Units (Low Income);
3 Units (Above Moderate Income)
(Moderate Income)
Total Capacity 37 Units 6 Units (Very Low Income); 6 Units (Low Income); 8 Units
(Moderate Income); 17 Units (Above Moderate Income)
El Camino Real Design Guidelines Consistency
The project is also subject to the El Camino Design Guidelines and South El Camino Design
Guidelines to the extent that these guidelines include objective standards. The design
guidelines are intended to direct the project design process toward solutions that, given site
conditions and the requirements of the development program, best meet City goals and
community values and expectations. Notable recommendations include landscaping buffers,
screening of mechanical equipment and parking areas, pedestrian oriented designs in the CN
district, minimizing the number of driveways, limiting building colors to no more than three
primary colors, and defining corner elements. As proposed, the project is generally consistent
with these guidelines, although only objective standards may be applied to the project. Where
the guidelines encourage specific requirements such as colors and defining corner elements,
the project complies with the related objective standards set forth under PAMC Chapter 18.24.
Although the project does not include a ground floor commercial use and, accordingly, does not
provide ground floor glazing/transparency, ground floor commercial uses are not required for
Housing Inventory Sites as noted in PAMC Section 18.14.020(b)(i).
these lots, including portions zoned CN, CS, RM-30, and RM-40. However, the site is located
within the El Camino Real Focus Area. The El Camino Real Focus Area modifies and replaces
some of the development standards provided in base zone districts and applicable combining
district regulations for housing development projects. In some instances, the El Camino Real
Focus Area standards refer to the governing base district regulations. Therefore, Attachment C
includes a summary of the project’s consistency with the El Camino Real Focus Area standards
as it would apply to each zone district on the site. Additionally, Attachment D includes a
summary of the project’s consistency with the objective design standards set forth in PAMC
Chapter 18.24.
Multi-Modal Access
Valley Transportation Authority (VTA) bus line 22 operates along El Camino Real, with a bus
stop located near the far northern corner of the project site. The project is located
approximately 1.2 miles from the California Avenue Caltrain Station and fronts El Camino Real.
California Department of Transportation recently installed Class III and Class IV bicycle facilities
along El Camino Real adjacent to the project frontage, further enhancing multimodal access for
cyclists.
Members of the public also expressed concern with respect to bicycle and pedestrian safety
associated with the location of the garage entrances, particularly due to concern that the
garage entrance on Matadero Avenue conflicts with the Safe Routes to School Route for Barron
Park Elementary School. However, the project includes widening of the right-of-way along
Matadero Avenue and Kendall Avenue to create a new sidewalk where no sidewalks currently
exist, improving pedestrian safety on both of these collector streets, though it may be noted
that this safety enhancement is somewhat out of character for the Barron Park neighborhood,
which generally does not include sidewalks. Additionally, although this project would result in
more cars entering and exiting the site on Matadero Avenue (in comparison to existing
conditions) the overall risk of conflict is less with the proposed design than it would be for a
design with curb cut(s) along El Camino Real, due to the lower volume of cars and lower speeds
on Matadero Avenue.
3, particularly to assess site specific
circulation as a result of the project. Although the applicant expressed that this report was
being prepared, it was not possible to complete the report within the strict timelines required
by AB 130 and the City cannot delay the decision on the project because one has not yet been
provided. Therefore, a condition of approval has been added to require the preparation of this
report and that recommended measures identified in the report to address safety be
implemented and reflected in the plans submitted for building permit.
Parking and Loading
3 June 15, 2020, City Council Resolution 9894 (Palo Alto Local Transportation Impact Analysis Policy):
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=61625&dbid=0&repo=PaloAlto
School Route; 2) a loading space is already provided within the parking garage adjacent to the
lobby; 3) additional loading spaces are not required; and 4) the applicant does not have rights
to the City’s right-of-way, a condition of approval has been added requiring that the proposed
loading zone on Matadero Avenue be removed on the plans submitted for building permit.
FISCAL/RESOURCE IMPACT
of the additional property tax generated. This project is also subject to Development Impact
Fees, currently estimated at $16,719,081.12, plus the applicable public art fee. These fees are
required to either be paid at building permit issuance or, with the recordation of a lien on the
property, may deferred until occupancy.
STAKEHOLDER ENGAGEMENT
Driveway location and site access design, including potential conflicts with bicyclists and
pedestrians along Matadero Avenue.
Public safety risks during catastrophic events, including earthquakes and fires.
Potential impacts to safe routes to school.
The public benefit of delivering approximately 300 new rental housing units.
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
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DRAFT ACTION NO. 2026-__
On _________, 2026, the City Council of the City of Palo Alto (“City Council”) approved a
Major Architectural Review application and Vesting Tentative Map for development of 321
residential rental units (“the project”). In approving the application, Council makes the
following findings, determinations, and declarations:
SECTION 1. Background.
A. On February 15, 2024, Camino Real Development LLC & Kendall Investors,
LLC filed a compliant pre-application in accordance with Senate Bill (SB) 330 and with California
Government Code Section 65589.5(d)(5) (also known as Builder’s Remedy).
B. On June 10, 2024, Camino Real Development LLC & Kendall Investors filed an
Architectural Review application (24PLN-00162) for construction of a 321 rental unit residential
project. In addition, Camino Real Development LLC & Kendall Investors filed an application for a
Vesting Tentative Map (25PLN-00243) on September 9, 2025, to merge seven existing lots to
create a single resulting 113,907-square-foot parcel (2.62 acres). The project includes 284 base
units and 37 density bonus units, for a total of 321 units, as well as the following density bonus
waivers and concessions in accordance with State Density Bonus Law, and additional protections
as a “builder’s remedy project,” under AB 1893:
Waiver 1: Build-to-lines (90% of frontage built to setbacks where a maximum
50% along El Camino Real is required)
Waiver 2: Upper Story Step Back (None proposed where a 10-foot step-back
above 55 feet in height is required)
Waiver 3: Lot Coverage (83% where maximum 80% is allowed)
Waiver 4: Rear setback (11 feet - 15 feet where a minimum 16 feet is required)
Waiver 5: Rear and Side Daylight Plane (None provided where 10 feet at lot
line then 45-degree angle is required)
Waiver 6: Housing typologies (More than two-acre lots are required to
provide a minimum of three housing types)
C. The project site is comprised of seven existing lots: APN No. 137-08-088,
approximately 10,838 square feet, developed with a commercial use; APN No. 137-08-016,
approximately 5,199 square feet, an undeveloped parcel; APN No. 137-08-079, approximately
10,194 square feet, developed with a commercial use; APN No. 137-08-080, approximately
28,350 square feet, an undeveloped parcel; APN No. 137-08-077, approximately 38,058 square
feet, developed with a multi-family residential use; APN No. 137-08-070, approximately 5,103
square feet, developed with a multi-family residential use; APN No. 137-08-081, approximately
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16,275 square feet, developed with a commercial and residential use. Adjacent uses include a
mix of commercial and low-intensity, one-story and two-story buildings, as well as low density
residential uses surrounded by surface parking.
Project and cumulative traffic safety analysis;
Sidewalk easements;
Relocating ingress/egress to improve pedestrian and bicycle safety and reduce
congestion near El Camino Real intersections; and
Incorporating portions of the site for a bike path.
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SECTION 2. Environmental Review. The City, as the lead agency for the Project, has determined
the project is exempt from California Environmental Quality Act (CEQA) in accordance with AB
130 [Public Resources Code section 21080.66]. Documentation to support the streamlined
review is available as part of the public record on file with the Planning and Development
Services Division.
Section 3. Architectural Review Findings. In order to make a recommendation of approval, the
project must comply with the following Findings for Architectural Review as required in Chapter
18.76.020 of the PAMC.
1.The design is consistent with applicable provisions of the Palo Alto Comprehensive Plan,
Zoning Code, coordinated area plans (including compatibility requirements), and any
relevant design guides.
A summary of the project’s consistency with the Comprehensive Plan is provided in this
table. Because the project is a “builder’s remedy project,” as defined in Gov. Code
section 65589.5(h)(11), and in accordance with Gov. Code section 65589.5(f)(6)(A), the
project is required to comply only with objective, quantifiable, written development
standards, conditions, and policies that would have applied to the project had it been
proposed on a site with a general plan designation and zoning classification that allow
the density and unit type proposed by the applicant. Moreover, in accordance with Gov.
Code section 65589.5(f)(6)(D)(iii), a project that complies with such objective standards,
conditions, and policies “shall be deemed consistent, compliant, and in conformity with
an applicable plan, program, policy, ordinance, standard, requirement, redevelopment
plan and implementing instruments, or other similar provision for all purposes.”
Comp Plan Goals and Policies How project adheres or does not adhere to
Comp Plan
The Comprehensive Plan land use designations
for the project site are Service Commercial
(CS), Neighborhood Commercial (CN), and
Multiple-Family Residential (MF) which
allow multifamily housing in specific locations.
The project site includes seven parcels with
varying Comprehensive Plan land use
designations, including Service Commercial,
Neighborhood Commercial, and Multiple-
Family Residential designations. Four of the
seven parcels on which the proposed project
would be located are identified as housing
inventory sites. The project adheres to the
Comprehensive Plan by providing housing on
these opportunity sites. The proposed multi-
family use is allowed within this land use
designation.
Housing Element
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Comp Plan Goals and Policies How project adheres or does not adhere to
Comp Plan
Policy 4.3 Implement development standards,
objective design standards, and architectural
and green building standards that encourage
new high-quality rental and ownership
housing.
The project complies with the implemented
standards except where requests for waivers or
concessions in accordance with state density
bonus law is provided. The project provides the
necessary upgrades to infrastructure on the
site to provide new high-quality rental
units. The project complies with all required
green building requirements in accordance
with state law and the city’s local reach code.
Land Use and Community Design Element
Goal L-1 A compact and resilient city providing
residents and visitors with attractive
neighborhoods, work places, shopping districts,
public facilities and open spaces.
The project redevelops existing developed
parcels and provides an attractive development
that is generally consistent with the City’s
design criteria.
Policy L-1.3: Infill development in the urban
service area should be compatible with its
surroundings and the overall scale and
character of the city to ensure a compact,
efficient development pattern.
The project is an urban infill development
proposal in the urban service area of the city.
Policy L-1.4: Commit to creating an inventory
of below market rate housing for purchase and
rental.
The proposed residential project includes 321
rental units, and 13 percent of the base 284
units (excluding density bonus units) would be
provided at a rate affordable to low-income
households or below. This would add 37 low
income rental units to the City’s BMR housing
stock.
Goal L-2 An enhanced sense of “community”
with development designed to foster public
life, meet citywide needs and embrace the
principles of sustainability.
The project is designed to comply with
CALGreen Tier 2 requirements that incorporate
sustainable design, construction, and
operational requirements to reduce energy and
water operational costs and in increase indoor
air quality for building owners and occupants.
Policy L-2.2 Enhance connections between
commercial and mixed use centers and the
surrounding residential neighborhoods by
promoting walkable and bikeable connections
and a diverse range of retail and services that
caters to the daily needs of residents.
The project site is located on and adjacent to El
Camino Real, a local serving and regional
serving corridor, defined by a mix of
commercial uses and housing. Caltrans recently
installed Class III and Class IV bike lanes, which
run along the project’s frontage on El Camino
Real. Residents would be able to utilize these
connections to other surrounding areas.
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Comp Plan Goals and Policies How project adheres or does not adhere to
Comp Plan
Goal L-6: Well-designed buildings that create
coherent development patterns and enhance
city streets.
The project frontage along El Camino Real
provides a sidewalk and retains the existing
four street trees. Alongside Matadero Avenue,
the project proposes two new street trees,
alongside Kendall Avenue five new street trees,
and four new trees alongside El Camino Real,
for an inviting streetscape. The project includes
high quality materials such as brick, wood, and
stucco that aid in creating a cohesive design.
Policy L-9.2 Encourage development that
creatively integrates parking into the project,
including by locating it behind buildings or
underground wherever possible, or by
providing for shared use of parking areas.
Encourage other alternatives to surface parking
lots that minimize the amount of land devoted
to parking while still maintaining safe streets,
street trees, a vibrant local economy and
sufficient parking to meet demand.
Parking would be screened behind the first
floor amenity spaces alongside El Camino Real
with the parking garage entrance located along
Matadero Avenue and Kendall Avenue. Further,
391 parking spaces would be provided on-site
exceeding the El Camino Real focus area
parking requirements.
Transportation Element
Policy T-3.7 Encourage pedestrian-friendly
design features such as sidewalks, street trees,
on-street parking, gathering spaces, gardens,
outdoor furniture, art and interesting
architectural details.
The project includes direct connections to the
sidewalk that help to activate the frontage
along El Camino Real in addition to new street
trees and plantings along Matadero Avenue,
Kendall Avenue, and El Camino Real.
Policy T-3.9 Support citywide sustainability
efforts by preserving and enhancing the tree
canopy where feasible within the public right-
of-way, consistent with the Urban Forest
Management Plan, as amended.
The project meets the tree canopy replacement
requirements through on-site plantings. The
project includes removal of 31 trees and
replaces with 129 trees, which are proposed to
be located along property lines, in the right of
way, and within open space areas.
The South El Camino Real Design Guidelines are applicable to the project, to the extent
that the standards are objective, and the site is located within the Triangle Area
Pedestrian Node. The project is consistent with the Guidelines, below is an analysis of
the applicable guidelines:
3.1.1 Effective Sidewalk Width:
Create a 12-foot effective sidewalk width
along El Camino Real
The project proposes a 12-foot effective
sidewalk width.
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3.1.2 Sidewalk Setback Design:
The design of the sidewalk setback should
create an urban “downtown” character.
The proposed sidewalk setback includes
areas for short-term bicycle parking and
architectural wall lights.
3.1.3 Build to lines:
Buildings should be built up to the sidewalk
to reinforce the definition and importance of
the street.
The project provides 90% built to the
setback while still providing the effective 12-
foot sidewalk width.
3.1.5 Minimum Height:
Buildings should have a minimum height of
25 feet in order to provide presence along El
Camino Real.
The project is 82 feet in height to the
parapets.
3.3.1 Usable Amenities:
Landscape and hardscape features should
not just be visually appealing, but also
function as open space amenities to be used
and enjoyed.
The project includes outdoor seating areas,
dining areas, and one pool.
4.1.8 Expression of Use:
Building forms should be articulated as an
expression of the building use.
The project has been revised to add
additional definition to the two-story
residential entry area at the building’s
corner. The balconies also provide visible
private outdoor space, identifying the
residential uses.
4.2.1 Relationship of Entries to the Street:
Buildings should have entries directly
accessible and visible from El Camino Real.
The building has a lobby facing El Camino
Real. The leasing entrance facing Matadero
Avenue and secondary entrance alongside
Kendall Avenue are visible from El Camino
Real.
4.3.6 Design Consistency on All Facades:
All exposed sides of a building should be
designed with the same level of care and
integrity.
All sides of the building use the same variety
of materials and level of detail. They are also
articulated for visual interest and to reduce
massing.
4.4.1 Amenities:
Building design should offer amenities to
users and the public such as protection from
the elements and places for people to gather
or retreat.
The project provides a number of public and
private gathering areas.
4.5.1 Flat Roofs and Parapets Encouraged.
Flat roofs with parapets are strongly
encouraged.
The proposed building has a flat roof with
parapet design.
4.8.1 Mix of Materials:
Juxtaposition of contrasting materials can
create interest when carefully integrated.
This project includes stucco, cast stone,
marble, brick, glass, and metal in a
composed design.
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2.The project has a unified and coherent design, that:
a.creates an internal sense of order and desirable environment for occupants,
visitors, and the general community,
b.preserves, respects and integrates existing natural features that contribute
positively to the site and the historic character including historic resources of the
area when relevant,
c.is consistent with the context-based design criteria of the applicable zone
district,
d.provides harmonious transitions in scale, mass and character to adjacent land
uses and land use designations,
e.enhances living conditions on the site (if it includes residential uses) and in
adjacent residential areas.
The project is consistent with Finding #2 because:
The project is comprised of various residential amenity spaces at the first floor, third floor, and
seventh floor and offers short-term bike racks for visitors and well as long-term bike lockers for
residents. There is pedestrian access adjacent to El Camino Real located on Matadero Avenue
and Kendall Avenue to promote walkability and connectivity. Cars enter the garage on
Matadero Avenue and Kendall Avenue as required per the objective standards. The pedestrian
walkways are paved with attractive materials and landscaped. The project proposes to
construct a building that is generally taller than the immediately surrounding buildings.
The proposed project is consistent with the findings to provide high quality materials and
finishes in a neutral color palette. The building will have residential amenity spaces on the first
floor with a majority of those spaces utilizing glazing, which helps to engage the sidewalk.
While the project at 82 feet in height exceeds surrounding development, the project complies
with the height limits within the El Camino Real Focus Area and deviates from the objective
standards in a manner consistent with state law.
3.The design is of high aesthetic quality, using high quality,
integrated materials and appropriate construction techniques, and incorporating
textures, colors, and other details that are compatible with and enhance the surrounding
area.
The project is consistent with Finding #3 because:
The project proposes a contemporary style that is recognizable along the El Camino corridor
overall and aligns with the recent residential development to the north of the project site. The
project uses materials such as stucco, cast stone, marble, brick, glass, and metal railings on the
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balconies and metal awnings. As conditioned, the stucco surfaces will be a smooth finish
texture. The proposed colors are neutral and are compatible with surrounding color schemes.
The design is functional, allowing for ease and safety of pedestrian and bicycle traffic
and providing for elements that support the building’s necessary operations
(e.g. convenient vehicle access to property and utilities, appropriate arrangement and
amount of open space and integrated signage, if applicable, etc.).
The landscape design complements and enhances the building design and its
surroundings, is appropriate to the site’s functions, and utilizes to the extent practical,
regional indigenous drought resistant plant material capable of providing desirable
habitat that can be appropriately maintained.
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6.The project incorporates design principles that achieve sustainability in areas related to
energy efficiency, water conservation, building materials, landscaping, and site
planning.
The project is consistent with Finding #6 because:
In accordance with the City’s Green Building Regulations, the project will satisfy the
requirements for CALGreen Mandatory + Tier 2. This is demonstrated on the GB sheets in the
plan set.
SECTION 4. Vesting Tentative Map Findings. A legislative body of a city shall deny approval of a
Subdivision Map, if it makes any of the following findings (California Government Code Section
66474). The City Council cannot make these findings for the following reasons:
1.That the proposed map is not consistent with applicable general and specific plans as
specified in Section 65451:
There is no adopted specific plan for this project site. The site is consistent with the
Comprehensive Plan as described below.
2.That the design or improvement of the proposed subdivision is not consistent with
applicable general and specific plans:
There is no adopted specific plan for this project site. The proposed Vesting Tentative Map and
related improvements is consistent with the Comprehensive Plan in that it facilitates housing
development on a site designated for multi-family use within the urban services area,
consistent with Goal 2 of the Housing Element and Goal L1.2 of the Land Use Element. The
project includes 321 Units, 37 of which would be provided at a rate affordable to low income.
The project improves the city’s jobs housing imbalance, consistent with the Transportation
Element’s goals and policies. Because the project is a “builder’s remedy project,” as defined in
Gov. Code section 65589.5(h)(11), and in accordance with Gov. Code section 65589.5(f)(6)(A),
the project is required to comply only with objective, quantifiable, written development
standards, conditions, and policies that would have applied to the project had it been proposed
on a site with a general plan designation and zoning classification that allow the density and
unit type proposed by the applicant. Moreover, in accordance with Gov. Code section
65589.5(f)(6)(D)(iii), a project that complies with such objective standards, conditions, and
policies “shall be deemed consistent, compliant, and in conformity with an applicable plan,
program, policy, ordinance, standard, requirement, redevelopment plan and implementing
instruments, or other similar provision for all purposes.”
3. That the site is not physically suitable for the type of development:
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The Project site is suitable for multi-family residential development in that the majority of the
parcels are identified as Housing Inventory Sites in the Housing Element. The project is also
located within the City’s El Camino Real Focus Area, an area identified for high density housing
within the City. The proposed parcel meets the minimum code requirements for the CN, CS,
RM-30, and RM-40 zone districts with respect to lot area, width, and depth. The proposed
number of apartment units created on the resulting parcel complies with the applicable
densities set forth in the land use element and zoning code, consistent with the focus area
standards. In addition, as noted above, the project is proposed pursuant to the “builder’s
remedy” of the Housing Accountability Act (Government Code section 65589.5) and is
consistent with the standards set forth therein.
That the site is not physically suitable for the proposed density of development:
5. That the design of the subdivision or the proposed improvements are likely to cause
substantial environmental damage or substantially and avoidably injure fish or wildlife
or their habitat:
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6. That the design of the subdivision or type of improvements is likely to cause serious
public health problems:
The record indicates that insufficient information has been provided to fully demonstrate that
the project would not create safety risks for bicyclists and pedestrians, including along safe
routes to school. Specifically, a traffic analysis has not yet been conducted for the site.
Cumulative impacts from proposed projects in the vicinity, including the project at 3400 El
Camino Real across Matadero Avenue, have not been evaluated.
Notwithstanding this inconsistency, the deviation is permitted under applicable State law,
which limits the City’s ability to deny based on such impacts. The proposed multi-family use
would not include use or storage of hazardous materials and the use is located within the urban
environment adjacent to other commercial uses. The site is not located on a hazardous waste
site pursuant to government code 65962.5. However, a portion of the site was previously a
gasoline service station that had its underground storage tanks removed and issued a Fuel Leak
Site Case Closure letter on July 23, 1997. Additional cleanup of the site for residential uses per
standard requirements will be included in the conditions of approval for the proposed
improvements.
7. That the design of the subdivision or the type of improvements will conflict with
easements, acquired by the public at large, for access through or use of, property within
the proposed subdivision. In this connection, the governing body may approve a map if
it finds that alternate easements, for access or for use, will be provided, and that these
will be substantially equivalent to ones previously acquired by the public. This subsection
shall apply only to easements of record or to easements established by judgment of a
court of competent jurisdiction and no authority is hereby granted to a legislative body
to determine that the public at large has acquired easements for access through or use
of property within the proposed subdivision.
There are no public access easements over the property currently. Therefore, the design of the
subdivision will not conflict with any public easements for access through, or use of, the
property. New public utility easements will be provided to existing and proposed electrical
utilities as part of this subdivision map as required in accordance with City of Palo Alto Utilities
standards. New public access easements will be provided to provide the 12-foot effective
sidewalk width along El Camino Real, consistent with project plans and City requirements.
SECTION 5. Vesting Tentative Map Approval Granted. Vesting Tentative Map Approval is filed
and processed in accordance to PAMC Section 21.13.020 and granted by the City Council under
PAMC Sections 21.12 and 21.20 and the California Government Code Section 66474, subject to
the conditions of approval in Section 8 of this Record of Land Use Action.
SECTION 6. Final Map. The Final Map submitted for review and approval by the City Council
shall be in substantial conformance with the Vesting Tentative Map prepared by Kier+Wright
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titled “VESTING TENTATIVE MAP” consisting of eleven pages, dated and submitted February 3,
2026, except as modified to incorporate the conditions of approval in Section 8. A copy of the
Vesting Tentative Map is on file in the Department of Planning and Development Services,
Current Planning Division. Prior to the expiration of the Vesting Tentative Map approval, the
subdivider shall cause the subdivision or any part thereof to be surveyed, and a Final Map, as
specified in Chapter 21.08, to be prepared in conformance with the Vesting Tentative Map as
conditionally approved, and in compliance with the provisions of the Subdivision Map Act and
PAMC Title 21 and submitted to the City Engineer (PAMC Section 21.16.010[a]).
Planning
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5. PROJECT MODIFICATIONS. All modifications to the approved project shall be submitted for
review and approval prior to construction. If during the Building Permit review and
construction phase, the project is modified by the applicant, it is the responsibility of the
applicant to contact the Planning Division/project planner directly to obtain approval of the
project modification.
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longer reliant on the nest). A report documenting any data recovered during monitoring
shall be prepared by a qualified biologist and submitted to the Director of Planning prior to
final planning inspection.
9. CULTURAL SENSITIVITY TRAINING. Prior to issuance of any grading permit, the project
applicant shall be required to submit evidence that a Cultural Awareness Training program
has been provided to construction personnel. The training shall be facilitated by a qualified
archaeologist in collaboration with a Native American representative registered with the
Native American Heritage Commission for the City of Palo Alto and that is traditionally and
culturally affiliated with the geographic area as described in Public Resources Code Section
21080.3.
10. SUB-SURFACE MONITORING. Prior to issuance of any tree removal, grading, demolition,
and/or building permits or activities, the applicant shall notify the Director of Planning, of
grading and construction dates and activities that require a qualified archeologist and
Native American monitor to be present on the project site. The City shall then notify the
tribe via e-mail correspondence 10 days prior to any grading or construction activities. If the
tribe chooses not to send a monitor or does not respond within the 10 days, work shall
continue without the monitor.
11. ARCHEOLOGICAL AND CULTURAL MONITORING. A qualified archaeologist and a Native
American monitor, registered with the Native American Heritage Commission for the City of
Palo Alto and that is traditionally and culturally affiliated with the geographic area as
described in Public Resources Code Section 21080.3, shall be present during earthmoving
activities including, trenching, initial or full grading, scraping or blading, lifting of
foundation, boring, drilling, or major landscaping. The qualified archaeologist and Native
American monitor shall have the authority to halt construction activities within 50 feet of a
discovery in the event any cultural materials are encountered during ground-disturbing
construction activities. The qualified archeologist and Native American monitor shall keep a
daily monitoring log on days that monitoring occurs documenting construction activities
that were monitored, location of the monitoring, and any cultural materials identified.
These daily monitoring logs shall be made available to the City upon request.
12. ARCHEOLOGICAL AND CULTURAL TREATMENT PLAN. In the event any significant cultural
materials are encountered during construction, construction within a radius of 50 feet of
the find would be halted, the Director of Planning shall be notified, and the on-site qualified
archaeologist, in collaboration with the Native American Monitor, shall examine the find
and make appropriate recommendations regarding the significance of the find and the
appropriate treatment of the resource.
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The qualified archeologist in collaboration with a Native American monitor, registered with
the Native American Heritage Commission for the City of Palo Alto and that is traditionally
and culturally affiliated with the geographic area as described in Public Resources Code
Section 21080.3, shall prepare and implement a treatment plan that reflects permit-level
detail pertaining to depths and locations of excavation activities. The treatment plan shall
contain, at a minimum:
a. Identification of the scope of work and range of subsurface effects (including
location map and development plan), including requirements for preliminary
field investigations.
b. Description of the environmental setting (past and present) and the
historic/prehistoric background of the parcel (potential range of what might be
found).
c. Monitoring schedules and individuals.
d. Development of research questions and goals to be addressed by the
investigation (what is significant vs. what is redundant information).
e. Detailed field strategy to record, recover, or avoid the finds and address research
goals.
f. Analytical methods.
g. Report structure and outline of document contents.
h. Disposition of the artifacts.
i. Security approaches or protocols for finds.
j. Appendices: all site records, correspondence, and consultation with Native
Americans, etc.
The treatment plan shall utilize data recovery methods to reduce impacts on subsurface
resources. The treatment plan must be reviewed and approved by the Director of Planning,
or the Director’s designee prior to implementation of the plan.
13. ARCHEOLOGICAL AND CULTURAL EVALUATION. The project applicant shall notify the
Director of Planning, Native American Monitor, and Archeological Monitor, of any finds
during grading or other construction activities. Any historic or prehistoric material identified
in the project area during excavation activities shall be evaluated for eligibility for listing in
the California Register of Historic Resources as determined by the California Office of
Historic Preservation. Data recovery methods may include, but are not limited to, backhoe
trenching, shovel test, hand augering, and hand-excavation. The techniques used for data
recovery shall follow the protocols identified in the approved treatment plan. Data recovery
shall include excavation and exposure of features, field documentation, and recordation. All
documentation and recordation shall be submitted to the Northwest Information Center,
and the Director of Planning.
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14. UNANTICIPATED DISCOVERY OF BURIED ARCHEOLOGICAL AND TRIBAL CULTURAL
RESOURCES. If human remains are found, the State of California Health and Safety Code
Section 7050.5 states that no further disturbance shall occur until the County Coroner has
made a determination of origin and disposition pursuant to Public Resources Code Section
5097.98. In the event of an unanticipated discovery of human remains, the County Coroner
must be notified immediately. If the human remains are determined to be of Native
American origin, the Coroner will notify the Native American Heritage Commission, which
will determine and notify a most likely descendant (MLD). The MLD has 48 hours from being
granted site access to make recommendations for the disposition of the remains. If the MLD
does not make recommendations within 48 hours, the landowner shall reinter the remains
in an area of the property secure from subsequent disturbance.
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16. NOISE MITIGATION IN CONFORMANCE WITH COMPREHNSIVE PLAN POLICY N6.11.1 AND
MITIGATION MEASURE NOISE-8 IN THE COMPREHENSIVE PLAN EIR. Noise control measures
would include, but not be limited to, the following BMPs that would further decrease the
project’s noise impacts during construction:
The contractor shall use “new technology” power construction equipment with
state-of-the art noise shielding and muffling devices. All internal combustion engines
used on the project site shall be equipped with adequate mufflers and shall be in
good mechanical condition to minimize noise created by faulty or poorly maintained
engines or other components.
The unnecessary idling of internal combustion engines shall be prohibited.
Staging areas and stationary noise-generating equipment shall be located as far as
possible from noise-sensitive receptors such as residential uses (a minimum of 200
feet)
The surrounding neighborhood shall be notified early and frequently of the
construction activities.
A “noise disturbance coordinator” shall be designated to respond to any local
complaints about construction noise. The disturbance coordinator would determine
the cause of the noise complaints (e.g., beginning work too early, bad muffler, etc.)
and institute reasonable measures warranted to correct the problem. A telephone
number for the disturbance coordinator would be conspicuously posted at the
construction site.
Utilize ‘quiet’ models of air compressors and other stationary noise sources where
technology exists.
Equip all internal combustion engine-driven equipment with mufflers, which are in
good condition and appropriate for the equipment.
Construct temporary noise barriers, where feasible, to screen stationary noise-
generating equipment when located within 200 feet of adjoining sensitive land uses.
Temporary noise barrier fences would provide a 5dBA noise reduction if the noise
barrier interrupts the line of- sight between the noise source and receptor and if the
barrier is constructed in a manner that eliminates any cracks or gaps.
If stationary noise-generating equipment must be located near receptors, adequate
muffling (with enclosures where feasible and appropriate) shall be used. Any
enclosure openings or venting shall face away from sensitive receptors.
Ensure that generators, compressors, and pumps are housed in acoustical
enclosures.
Locate cranes as far from adjoining noise-sensitive receptors as possible.
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During final grading, substitute graders for bulldozers, where feasible. Wheeled
heavy equipment are quieter than track equipment and should be used where
feasible.
Substitute nail guns for manual hammering, where feasible.
Substitute electrically powered tools for noisier pneumatic tools, where feasible.
Prior to building permit issuance the contractor shall prepare a detailed construction
plan identifying the schedule for major noise-generating construction activities. The
construction plan shall identify a procedure for coordination with adjacent
residential land uses so that construction activities can be scheduled to minimize
noise disturbance.
17. NOISE MITIGATION IN CONFORMANCE WITH COMPREHNSIVE POLICY N6.11.1 AND
MITIGATION MEASURE NOISE-5a IN THE COMPREHENSIVE PLAN EIR. The project proponent
shall implement a construction vibration monitoring plan to document conditions prior to,
during, and after vibration generating construction activities for the adjacent residential
uses. All plan tasks shall be undertaken under the direction of a licensed Professional
Structural Engineer in the State of California and be in accordance with industry-accepted
standard methods. The construction vibration monitoring plan shall be submitted to the
City prior to issuance of a Grading or Building Permit and shall include, but not be limited to,
the following measures:
The report shall include a description of measurement methods, equipment used,
calibration certificates, and graphics as required to clearly identify vibration-
monitoring locations.
A list of all heavy construction equipment to be used for this project and the
anticipated time duration of using the equipment that is known to produce high
vibration levels (clam shovel drops, vibratory rollers, hoe rams, large bulldozers,
caisson drillings, loaded trucks, jackhammers, etc.) shall be submitted to the Director
of Planning and Development Services or Director’s designee of the Department of
Planning & Development by the contractor. This list shall be used to identify
equipment and activities that could exceed the 0.3 PPV threshold at the adjacent
residential uses based on the planned equipment, location, and duration of use.
Where project construction activities may be anticipated to exceed the threshold,
the applicant shall provide a plan to show how levels would be reduced by phasing
activities that are known to cause excessive vibration, utilizing alternative
equipment, and/or reducing the time period that the equipment is being used.
Where possible, use of the heavy vibration-generating construction equipment shall
be prohibited within 20 feet of the adjacent residential uses.
o Smaller equipment (less than 18,000 pounds) must be used near the
property lines adjacent to the existing residential uses to minimize vibration
levels to 0.3 in/sec PPV or less. For example, a smaller vibratory roller similar
to a Caterpillar model CP433E vibratory compactor could be used when
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compacting materials within 20 feet of the adjacent residential buildings. The smaller
equipment intended to implement this requirement shall be individually identified
among the list of equipment required under the above condition as the subset of
equipment allowed for use at the property lines.
o Avoid using vibratory rollers and clam shovel drops within 20 feet of the
adjacent residential uses.
o Select demolition methods that do not involve large impact tools such as
hoe-rams within 20 feet of the eastern property line. Portable jackhammers,
saws, or grinders shall be used to minimize impacts to the ground.
o Avoid dropping heavy equipment and use alternative methods for breaking
up existing pavement, such as a pavement grinder, instead of dropping heavy
objects, within 20 feet of the adjacent residential uses.
• Develop a vibration monitoring and construction contingency plan to identify
structures where monitoring would be conducted, set up a vibration monitoring
schedule, define structure-specific vibration limits, and address the need to conduct
photo, elevation, and crack surveys to document before and after construction
conditions. Construction contingencies shall be identified for when vibration levels
approach the limits of 0.3 in/sec PPV at the adjacent residential buildings.
• At a minimum, vibration monitoring shall be conducted during demolition and
excavation activities.
• Designate a person responsible for registering and investigating claims of excessive
vibration. The contact information of such person shall be clearly posted on the
construction site.
Conduct a post-construction survey on structures where either monitoring has
indicated high vibration levels or complaints of damage has been made. Make
appropriate repairs or compensation where damage has occurred as a result of
construction activities.
18. OPEN AIR LOUDSPEAKERS (AMPLIFIED MUSIC). In accordance with PAMC Section 9.12, no
amplified music shall be used for producing sound in or upon any open area, to which the
public has access, between the hours of 11:00pm and one hour after sunrise. In addition, all
rooftop gardens/decks shall comply with the provisions of PAMC 18.42.230.
19. NOISE THRESHOLDS ON RESIDENTIAL PROPERTY. NOISE THRESHOLDS ON RESIDENTIAL
PROPERTY. In accordance with PAMC Section 9.10.030, No person shall produce, suffer or
allow to be produced by any machine, animal or device, or any combination of same, on
residential property, a noise level more than six dB above the local ambient at any point
outside of the property plane. At building permit, provide the proposed HVAC
specifications. If the proposed decibel level of the HVAC exceeds the decibel level of the
HVAC evaluated in the CEQA analysis, a noise analysis of the proposed equipment’s
consistency with the municipal code shall be required.
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20.NOISE REPORT PRIOR TO INSPECTION. Where the acoustical analysis projected noise levels
at or within 5 dB less than the Noise Ordinance limits, the applicant shall demonstrate the
installed equipment complies with the anticipated noise levels and the Noise Ordinance
prior to final Planning inspection approval.
$17,698,233.70 shall be paid in accordance with PAMC Chapter 16.64. The final
Development Impact Fees shall be calculated before they are due, and payment may be
deferred to the date the development is approved for occupancy as set forth in PAMC
Section 16.64.030 and as permitted by SB 937.
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YOU FAIL TO INITIATE A PROTEST WITHIN THE 90-DAY PERIOD OR FOLLOW THE PROTEST
PROCEDURES DESCRIBED IN GOVERNMENT CODE SECTION 66020, YOU WILL BE BARRED
FROM CHALLENGING THE VALIDITY OR REASONABLENESS OF THE FEES, DEDICATIONS,
RESERVATIONS, AND EXACTIONS. If these requirements constitute fees, taxes,
assessments, dedications, reservations, or other exactions as specified in Government Code
Sections 66020(a) or 66021, this is to provide notification that, as of the date of this notice,
the 90-day period has begun in which you may protest these requirements. This matter is
subject to the California Code of Civil Procedures (CCP) Section 1094.5; the time by which
judicial review must be sought is governed by CCP Section 1094.6.
27. INDEMNITY. To the extent permitted by law, the Applicant shall indemnify and hold
harmless the City, its City Council, its officers, employees and agents (the “indemnified
parties”) from and against any claim, action, or proceeding brought by a third party against
the indemnified parties and the applicant to attack, set aside or void, any permit or
approval authorized hereby for the Project, including (without limitation) reimbursing the
City for its actual attorneys’ fees and costs incurred in defense of the litigation. The City
may, in its sole discretion, elect to defend any such action with attorneys of its own choice.
28. FINAL INSPECTION. A Planning Division Final inspection will be required to determine
substantial compliance with the approved plans prior to the scheduling of a Building Division
final. Any revisions during the building process must be approved by Planning. Contact your
Project Planner, Steven Switzer at Steven.Switzer@PaloAlto.gov to schedule this inspection.
Public Art
29. The project triggers the Public Art in Private Development ordinance, requiring that 1% of the
estimated cost of construction be spent either on art on-site, or the payment of the
equivalent funds to the Public Art Fund in-lieu of commissioning artwork on site. The
applicant has not submitted a public art application at this time. Prior to issuance of a building
permit, the applicant shall pay the required in-lieu contribution to the Public Art Fund or,
prior to applying for a building permit, shall file a minor architectural review application to
evaluate proposed public art, which shall be reviewed and approved by the public art
commission. The Public Art Program team will need to verify the Construction Valuation with
an outside consultant. Contact the Public Art Program at the time you apply for Building
permit to begin this verification process. All information and application materials may be
found at paloalto.gov/public art under the Policies and Documents tab. In-lieu fees may be
paid at occupancy in accordance with the requirements under PAMC 16.64.030 and as
permitted by SB 937.
Building Division
30. A complete construction set shall be submitted to the building department for review. A
complete construction shall include, but is not limited to: architectural drawings, structural
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drawings and calculations, mechanical plans, electrical plans, plumbing plans, and Title 24
energy analysis.
31. All sheets shall be stamped and signed by the responsible designer.
32. Refer to this website below for additional building permit submittal requirements. Contact
the building department for any questions.
https://www.paloalto.gov/files/assets/public/v/3/development-services/building-
division/checklists/simplified/c1-new-comm-shell-checklist-07062023.pdf
Transportation
33. Prior to issuance of a building permit, the applicant shall obtain a transportation analysis
(TA) consistent with the City's Local Transportation Impact Analysis Policy and prepared by a
consultant reasonably acceptable to the City. The applicant shall implement any mediation
measures recommended in the TA that would not render the project infeasible. Potential
mediation measures could include but not limited to; flex posts, bike boxes, bike sharrows,
and/or speed bumps. At a minimum, the TA shall:
a. Evaluate project ingress and egress operations, including driveway functionality
and queuing;
b. Analyze intersection operations and impacts at the Matadero Avenue / El
Camino Real and Kendall Avenue / El Camino Real intersections, considering the
existing “No Right Turn on Red” restrictions;
c. Evaluate potential impacts to the suggested school route along Matadero
Avenue and Kendall Avenue with respect to multimodal access; and
d. Identify and recommend improvements as necessary, subject to City approval.
34. OFF SITE IMPROVEMENTS: Off-site improvement plans shall be submitted to the Office
of Transportation for review and approval. These improvements shall incorporate all
recommendations identified in the transportation analysis prepared for the project. Off-
site improvements include, but are not limited to, design modifications that support on
site circulation and prevent queuing or other operational deficiencies within the public
right of way. Any proposed modifications to the public right of way shall be evaluated to
ensure they can be safely accommodated given existing lane geometry.
35. TRANSPORTATION DEMAND MANAGEMENT (TDM): The applicant shall prepare and
submit a final TDM Plan consistent with the Comprehensive Plan policies for the El
Camino Real corridor and that demonstrates a minimum 30 percent reduction in project
generated vehicle trips. The plan shall identify parking and trip reduction measures,
include trip targets and a monitoring and enforcement mechanism, and designate the
responsible entity for implementation.
All approved TDM measures shall be maintained for the life of the project. Monitoring
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reports shall be submitted two years after occupancy and annually thereafter. If
performance targets are not met, the applicant shall implement modifications as
required by the Director. Failure to correct deficiencies may result in administrative
penalties or other enforcement actions consistent with the Municipal Code.
36. BICYCLE PARKING: In accordance with California Green Building Standards Code
(CALGreen), the project shall provide one on-site short term bicycle parking space per
10,000 square feet. Short term bicycle parking spaces shall be located within 200 feet of
building entrances and readily visible to passers-by.
37. LOADING ZONES: No project dedicated loading space shall be located within the public
right of way. The project shall maintain at minimum one, on-site loading space.
38. CONSISTENCY WITH CALTRANS SR-82 IMPROVEMENTS: All off site improvements shall
be consistent with the recently completed Caltrans SR 82 (El Camino Real)
improvements, including existing “No Parking” signage along El Camino Real. Any
temporary alterations to bike lane enhancements shall be restored to existing
conditions upon completion of the project.
39. BUS SHELTER COORDINATION: Potential impacts to the existing VTA bus shelter at the
intersection of Matadero Avenue and El Camino Real shall be reviewed and approved
through VTA’s development review process. The applicant shall comply with all
requirements issued by the transit authority.
40. DRIVEWAY SIGHT LINES: Adequate sight distance shall be preserved at all driveways.
a. Landscaping within driveway vision triangles shall be maintained at a maximum
height of three (3) feet.
b. All new and existing trees shall be maintained to provide a minimum vertical
clearance of seven (7) feet above grade to ensure unobstructed visibility.
41. QUEUING: Fast opening gates shall be installed and maintained to ensure that vehicle
queuing does not extend into or impact the public right of way.
42. TRASH REMOVAL AND OPERATIONS: Trash bin staging and collection operations shall
occur entirely on site and shall not encroach into or occur within the public right of way.
Public Works Zero Waste
43. REQUIRED DECONSTRUCTION. In conformance with PAMC 5.24, deconstruction and source
separation are required for all residential and commercial projects where structures (other
than a garage or ADU) are being completely removed, demolition is no longer allowed.
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Deconstruction takes longer than traditional demolition, it is important to plan ahead. For
more information, visit www.cityofpaloalto.org/deconstruction.
44. SALVAGE SURVEY FOR REUSE. A Salvage Survey is required for deconstruction permit
applications. The survey shall be conducted by a City approved reuse vendor. The survey
submittal shall include an itemized list of materials that are salvageable for reuse from the
project. The applicant shall source separate and deliver materials for reuse. Certification is
required indicating that all materials identified in the survey are properly salvaged. Contact
The ReUse People to schedule this FREE survey by phone (888) 588-9490 or e-mail
info@thereusepeople.org. More information can be found at www.TheReusePeople.org.
Please upload a completed copy to the deconstruction permit.
45. SOURCE SEPARATION FOR RECYCLING. The applicant shall source separate deconstruction
materials into specific categories for recycling. Additional staging areas for source separated
materials will need to be considered. All materials shall be delivered to one of the City
approved materials recovery facilities listed in Green Halo, all records shall be uploaded to
www.greenhalosystems.com.
For more information, refer to www. paloalto.gov/deconstruction. Trash enclosure can only
be used to temporarily store refuse (garbage, recycling, and compost) and not for other
storage.
46. On the plans submitted for building permit provide cut-sheets for the color-coded internal
and external containers, related color-coded millwork, and its colored signage in the
building plans. Trash chutes must have colored doors with colored signage that complies
with PAMC 5.20.18 requirements.
47. All indoor and outdoor common spaces are required to comply with the following: As per
Palo Alto Municipal Code 5.20.108 the site is required to have color-coded refuse
containers, related color-coded millwork, and colored signage. The three refuse containers
shall include recycle (blue container), compost (green container), and garbage (black
container). Applicant shall present on the plan submitted for building permit the locations
and quantity of both (any) internal and external refuse containers, it’s millwork, along with
the signage. However, for the copy/ mail area must have either a recycle bin only or all
three refuse receptacles (green compost, blue recycle, and black landfill container). Please
refer to PAMC 5.20.108 and the Internal Container Guide. Examples of appropriate signage
can be found in the Managing Zero Waste at Your Business Guide. Electronic copies of these
signage can be found on the Zero Waste Palo Alto’s website,
https://www.paloalto.gov/Departments/Public-Works/Zero-Waste/What-Goes-
Where/Toolkit#section-2 and hard copies can be requested from the waste hauler,
Greenwaste of Palo Alto, (650) 493-4894.
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Public Works Engineering
48. PUBLIC WORKS APPLICATIONS, FORMS, AND DOCUMENTS: Applicant shall be advised
that most forms, applications, and informational documents related to Public Works
Engineering conditions can be found at the following link:
https://www.cityofpaloalto.org/Departments/Public-Works/Engineering-
Services/Forms-and-Permits
49. OVERVIEW AND GUIDELINES FOR THE REVIEW OF SUBDIVISION PROJECTS: Developer
shall familiarize themselves with the guidelines described in the November 2007
revision of the document titled “Overview and Guidelines for the Review of Subdivision
Projects”. Particularly Section II (items 5 through 12) and Section V (items A through C).
https://www.paloalto.gov/files/assets/public/planning-amp-development-services/file-
migration/current-planning/forms-and-guidelines/overview-and-guidelines-for-the-
review-of-subdivision-projects.pdf
50. PARCEL MAP/FINAL MAP: Approval of this application is subject to, and contingent upon
the approval of a tentative map and recordation of a Final Map, as detailed in Section 8.
51. STREETWORK PERMIT: The applicant shall obtain a Streetwork Permit from the
Department of Public Works for all public improvements.
52. SPECIAL STREET LIGHT: This project is located within an area designated to have special
streetlights as shown in the Special Street Light Style Placement Guide. Any new or
replaced streetlights shall be installed to the standards adopted by the Public Works
Department and Utility Department.
https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development-
services/current-planning/pw-style-placement-guide-2020.pdf
53. UPGRADE OF EXISTING PUBLIC IMPROVEMENTS: As part of the plan review for
improvements within the public right-of-way, any existing improvements to be re-used
by the project, which are not to current City standards and are not specifically in these
project conditions (such as streetlights, utility covers and lids, etc.), shall be upgraded to
current City standards as required by the Director of Public Works and the Director of
Utilities.
54. MODIFICATIONS TO EXISTING PUBLIC UTILITIES: The Developer is responsible for any
changes or modifications to existing utilities, streets, and public infrastructure within or
adjacent to the project site that are attributable to the development. This includes, but
is not limited to, the relocation of utility facilities, conduits, or vaults required due to
grade changes in the sidewalk area resulting from the development. The Developer’s
financial responsibility for utility upgrades exceeding the impacts of the development
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shall be limited to Developer’s fair share contribution, as reasonably determined by the
Utilities and/or Public Works Department.
55. DAMAGE TO EXISTING PUBLIC IMPROVEMENTS: The Developer is responsible for
repairing any damage to existing public improvements fronting or adjacent to the
project site caused by construction, to the satisfaction of the Public Works Department.
56. EXISTING UTILITY ABANDONMENT AND/OR RELOCATION: The Developer is responsible
for researching all existing utility lines to ensure there are no conflicts with the project.
Any existing utility lines (public or private) or their appurtenances that conflict with the
project or do not serve it must be capped, abandoned, removed, relocated, or disposed
of to the satisfaction of the City.
57. RE-USE OF EXISTING STORM DRAINS: The re-use of existing City storm drain service lines
and appurtenances is subject to City review and approval. The Developer’s contractor
shall expose the existing storm drain facilities during construction for City inspection or
provide video documentation of their condition. Any deficient facilities, as determined
by Public Works, must be replaced by the Developer. The Developer’s financial
responsibility for storm drain facility upgrades exceeding the impacts of the
development shall be limited to Developer’s fair share contribution, as reasonably
determined by the Public Works Department.
58. STORM DRAIN TRIBUTARY PATTERN: This project must follow the existing storm drain
tributary pattern. Any deviations require additional analysis and approval by Public
Works during plan review. The project shall not negatively impact the drainage pattern
for adjacent properties.
59. GRADING AND EXCAVATION PERMIT: A Grading Permit is required per PAMC Chapter
16.28. The permit application and all applicable documents (see Section H of
application) shall be submitted to Public Works Engineering. Add the following note:
“THIS GRADING PERMIT WILL ONLY AUTHORIZE GENERAL GRADING AND INSTALLATION
OF THE STORM DRAIN SYSTEM. OTHER BUILDING AND UTILITY IMPROVEMENTS ARE
SHOWN FOR REFERENCE INFORMATION ONLY AND ARE SUBJECT TO SEPARATE
BUILDING PERMIT APPROVAL.”
60. ROUGH GRADING: provide a Rough Grading Plan for the work proposed as part of the
Grading and Excavation Permit application. The Rough Grading Plans shall including the
following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over
excavation, stockpile area of material, overall earthwork volumes (cut and fill),
temporary shoring for any existing facilities, ramps for access, crane locations (if any),
tree protection measures, etc.
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61. CIVIL ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the
final completion of the work, applicant shall provide an as-graded grading plan prepared
by the civil engineer that includes original ground surface elevations, as-graded ground
surface elevations, lot drainage patterns and locations and elevations of all surface and
subsurface drainage facilities. The civil engineer shall certify that the work was done in
accordance with the final approved grading plan.
62. DIRECT CONNECTIONS TO STORM DRAIN SYSTEM: If the project proposes to replace
and/or add connections to the City maintained storm drain system, then the applicant
may be responsible for improvements to the system. These improvements may include,
but not limited to, upsizing the storm drain facility, replacing or adding City standard
catch basins, pipes and manholes. THIS MAY INCLUDE REPLACING BRICK AND MORTAR
MANHOLES. The extent of required improvements will be at the public works staff
discretion and shall be consistent with Storm Drain Master Plan and Public Works
Construction Standards. Any work on the city's storm drain systems requires permits
and inspection by Public Works inspectors. The Developer’s financial responsibility for
storm drain facility upgrades exceeding the impacts of the development shall be limited
to Developer’s fair share contribution, as reasonably determined by the Public Works
Department.
63. CCTV OF STORM DRAIN SYSTEM: Post construction the applicant may be required to
provide CCTV inspection of the City’s storm drain facilities to verify that any lines were
not broken, cracked or damaged during construction. The video shall be high resolution
and done by professional who is familiar with the process and meticulous. A CCTV
inspection video is required for new storm drain connection (s) to verify proper
connections were made into the City’s system and that no construction material was left
behind. Videos of storm drain system may also be required where construction occurred
less than 5-ft from the city’s storm drain system. Videos shall be provided from structure
to structure, such as manhole to manhole. Contractor may want to conduct their own
inspection in advance of construction to verify the existing pipe integrity. If existing
damages are located, they shall be reported to Public Works inspectors prior to the start
of construction. If not reported, the contractor may be responsible to restore the pipe
segment as determined by Public Works prior to final.
64. GEOTECHNICAL ENGINEER STATEMENT: The grading plans shall include the following
statement signed and sealed by the Geotechnical Engineer of Record: “THIS PLAN HAS
BEEN REVIEWED AND FOUND TO BE IN GENERAL CONFORMANCE WITH THE INTENT
AND PURPOSE OF THE GEOTECHNICAL REPORT”.
65. SWPPP: This proposed development will disturb more than one acre of land.
Accordingly, the applicant shall apply for coverage under the State Water Resources
Control Board’s (SWRCB) NPDES general permit for storm water discharge associated
with construction activity. A Notice of Intent (NOI) shall be filed for this project with the
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SWRCB in order to obtain coverage under the permit. The General Permit requires the
applicant to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP).
The applicant is required to submit two copies of the NOI and the draft SWPPP to the
Public Works Department for review and approval prior to issuance of the building
permit. The SWPPP should include both permanent, post-development project design
features and temporary measures employed during construction.
66. ENCROACHMENT PERMIT: Prior to any work in the public right-of-way, the applicant
shall obtain an encroachment permit from the Public Works Department for any work
that encroaches onto the City right-of-way.
67. LOGISTICS PLAN: A construction logistics plan shall be provided addressing all impacts
to the public including, at a minimum: work hours, noticing of affected businesses, bus
stop relocations, construction signage, dust control, noise control, storm water pollution
prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane
lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck
routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance,
Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may
require an encroachment permit.
68. STORMWATER POLLUTION PREVENTION: All improvement plan sets shall include the
“Pollution Prevention – It’s Part of the Plan” sheet.
69. C.3 THIRD-PARTY CERTIFICATION: Applicant shall provide certification from a qualified
third-party reviewer that the proposed permanent storm water pollution prevention
measures comply with the requirements of Provision C.3 and Palo Alto Municipal Code
Chapter 16.11. Submit the following:
a. Provide a stamped and signed C.3 data form (April 2024 version) from
SCVURPPP. https://scvurppp.org/2024/09/19/provision-c-3-data-form-2024/
b. Final stamped and signed letter confirming which documents were reviewed and
that the project complies with Provision C.3 and PAMC 16.11.
70. C.3 STORMWATER AGREEMENT: The applicant shall enter into a Stormwater
Maintenance Agreement with the City to guarantee the ongoing maintenance of the
permanent storm water pollution prevention measures. The City will inspect the
treatment measures yearly and charge an inspection fee. The agreement shall be
executed by the applicant team prior to building permit final.
71. C.3 FINAL THIRD PARTY CERTIFICATION PRIOR TO OCCUPANCY: Within 45 days of the
installation of the required storm water treatment measures and prior to the issuance
of an occupancy permit for the building, the third-party reviewer shall submit to the City
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a certification verifying that all the permanent storm water pollution prevention
measures were installed in accordance with the approved plans.
72. PAVEMENT RESTORATION: The applicant shall restore the pavement along the entire
project frontage, curb-to-curb, by performing a 3.5” grind and overlay. The exact
restoration limits will be determined once the resulting road condition is known
following completion of heavy construction activities and utility lateral installations, at
minimum the extent will be the project frontage on Matadero and Kendall Avenues. The
extent of restoration required on El Camino Real shall be determined by the Public
Works Department following completion of heavy construction activities and utility
lateral installations.
73. EXISTING EASEMENTS: Provide documentation showing approval from the entities
affected by the onsite easements to verify that the work within said easements is
permitted.
74. OUTSIDE AGENCY APPROVAL: A portion of the proposed work is within Caltrans right-of-
way. Evidence of permit approvals shall be submitted prior to issuance of City permits.
75. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (STORM DRAIN LOGO): The applicant is
required to paint “No Dumping/Flows to Matadero Creek” in blue on a white
background adjacent to all onsite storm drain inlets. The name of the creek to which
the proposed development drains can be obtained from Public Works Engineering.
Stencils of the logo are available from the Public Works Environmental Compliance
Division, which may be contacted at (650) 329-2598. Include the instruction to paint the
logos on the construction grading and drainage plan.
76. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (RECORD DRAWINGS): At the conclusion
of the project applicant shall provide digital as-built/record drawings of all
improvements constructed in the public right-of-way or easements in which the City
owns an interest.
77. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (INDEFINITE ENCROACHMENT PERMIT):
An approved indefinite encroachment permit will be required for any private
infrastructure constructed in the public right-of-way, easement or on property in which
the City holds an interest, but that was not authorized by a building permit.
Urban Forestry
78. Post building permit issuance all protected trees are subject to a 14-day public notice
prior to their removal.
79. URBAN FORESTRY GENERAL: The following general tree preservation measures apply to
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all trees to be retained: No storage of material, topsoil, vehicles or equipment shall be
permitted within the Tree Protection Zone (TPZ). The ground under and around the tree
canopy area shall not be altered. No waste material or construction byproducts are
allowed within the TPZ. Trees to be retained shall be irrigated, aerated, and maintained
as necessary to ensure survival.
80. TREE DAMAGE: Tree Damage, Injury Mitigation, and Inspections apply to the Contractor.
Reporting, injury mitigation measures, and arborist inspection schedule may apply
pursuant to TLTM, Section 5.03.6. Contractor shall be responsible for the repair or
replacement of any publicly owned or protected trees that are damaged during the
course of construction, pursuant to Title 8 of the Palo Alto Municipal Code, and City of
Palo Alto Tree and Landscape Technical Manual, Section 3.02.
81. TPZ EXCAVATION RESTRICTIONS APPLY - TLTM, Sec. 3.03.6 - B5,6: Any approved grading,
digging, potholing, or trenching within the TPZ of a protected tree shall be performed
using ‘air-spade’ method as a preference, with manual hand shovel as a backup. (TPZ=
10x the tree diameter at 54" above grade) For utility trenching, including sewer line,
roots exposed with a diameter of 2 inches and greater shall remain intact and not be
damaged. If directional boring method is used to tunnel beneath roots, then CPA
Standard Detail #504 shall be printed on the final plans and the buffer distances in TLTM
Table 3-4,Trenching and Tunneling Distance, shall be implemented by Contractor.
Contractor must notify the Urban Forestry Section at (650) 496-5953 in advance of
conducting any approved excavation within 10-feet of any street trees (or for any
protected tree on EVSE projects). Urban Forestry may choose to monitor or review the
work for compliance with the City’s Tree Protection Zone (TPZ) excavation standards.
82. TREE PROTECTION COMPLIANCE: The owner and contractor shall implement all
protection and inspection schedule measures, design recommendations, and
construction scheduling as stated in the Tree Preservation Report and/or T-1 Sheet Set
and is subject to code compliance action pursuant to PAMC 8.10.080. The required
protective fencing shall remain in place until the final landscaping or Urban Forestry
inspection of the project is completed.
83. NO NET LOSS OF CANOPY: In order to comply with the City’s no net loss of canopy policy
(PAMC 8.10.055; Urban Forest Master Plan Goals 6.A, 6.B, & 6.C; Comprehensive Plan,
Natural Environment Chapter Goal N-2) all trees 4 inches DBH and larger are subject to
replacement to avoid a loss of canopy at the neighborhood level. Replacement ratios
are determined by table 3-1 in the Tree and Landscape Technical Manual, Section 3.02.
New landscape tree plantings (24 inch box or larger) count towards the replacement
total. Screening trees may also count toward the total depending on size and species
selected. If unable to plant the required number of trees on site (our preferred solution)
there is the option of paying in-lieu fees per each 24 inch box tree into the forestry fund.
[Note: A replacement at ratio of 1:1 for trees listed as exempt species under PAMC
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8.10.020 is recommended. Exempt trees may require full replacement on parcels zoned
other than R1, RE, R-2, or RMD].
84. PLAN CHANGES: Revisions and/or changes to plans before or during construction shall
be reviewed and responded to by the (a) project site arborist, or (b) landscape architect
with written letter of acceptance before submitting the revision to Planning and
Development Services Department for review by Planning, Public Works, or Urban
Forestry.
85. PLAN SET REQUIREMENTS: The final Plans submitted for a building permit shall include
the location, DBH, canopy drip-line, and TPZ of all trees 4 inches DBH or greater as well
as the following information and notes on relevant plan sheets:
a. T-1 SHEET SET, The building permit plan set will include the City’s full-sized, T-1
Sheet Set (Tree Protection-it's Part of the Plan!), available on the Development
Center website. A certified arborist shall complete and sign the Tree Disclosure
Statement.
b. TREE PRESERVATION REPORT (TPR), if indicated by Tree Disclosure Statement, All
sheets of the Applicant’s TPR approved by the City for full implementation by
Contractor, shall be printed on numbered T-1 Sheets (T-3, T-4, etc.) and added to
the sheet index.
c. TREE PROTECTION FENCING, The Plan Set (esp. site, demolition, grading &
drainage, foundation, irrigation, tree disposition, utility sheets, etc.) must
delineate/show the correct configuration of Type I, Type II or Type III fencing
around each Protected Tree, using a bold dashed line enclosing the Tree
Protection Zone (CPA Standard Detail #605).
Fire
86. Fire sprinkler density of parking garage with EVCE shall be Extra Hazard-II. Install smoke
removal sys in parking garage.
87. Overhead utilities on both Kendall Ave and Matadero Ave shall be placed underground
along exterior walls of this project.
Watershed Protection
The following comments are provided as a courtesy and these conditions of approval must be
complied with before receiving a Demolition Permit for this project:
88. NOTICE OF REGULATION OF PCB MATERIAL – EFFECTIVE JULY 1st, 2019: Please be
advised that requirements regarding stormwater control during building demolition for
polychlorinated biphenyls (PCBs) became effective starting July 1st, 2019, in accordance
with the San Francisco Bay Region Municipal Regional Stormwater NPDES Permit (MRP),
Order No. R2-2015-0049. MRP Provision C.12.f. requires that San Francisco Bay Area
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municipalities develop a program to ensure that PCBs from building materials (e.g.
caulk, paint, mastic) do not enter the storm drain system during building demolition.
Palo Alto City Council adopted the PCBs regulation in May 2019. For specific questions
about your project, please email CleanBay@cityofpaloalto.org, call 650-329-2122 or visit
http://www.cityofpaloalto.org/pcbdemoprogram.
89. If the project is submitting a demolition permit application on or after July 1st, 2019, the
applicant shall complete and submit the “PCBs Applicant Package,” including any
required sampling reports (per the Applicant Package instructions), with the demolition
permit application. The PCBs Application Package and other resources are outlined at
http://www.cityofpaloalto.org/pcbdemoprogram. The Applicant Package will outline
PCBs sampling and reporting requirements that must be met if the project meets ALL of
the following conditions:
a. The project is a commercial, public, institutional, or industrial structure
constructed or remodeled between January 1, 1950 and December 31, 1980.
Single-family and two-family homes are exempt regardless of age.
b. The framing of the building contains material other than wood. Wood-frame
structures are exempt.
c. The proposed demolition is a complete demolition of the building. Partial
demolitions do not apply to the requirements.
90. If the project triggers polychlorinated biphenyls (PCBs) sampling as identified on the
“PCBs Applicant Package,” then the project shall conduct representative sampling of
PCBs concentration in accordance with the “Protocol for Evaluating Priority PCBs-
Containing Materials before Building Demolition (2018).”
If the representative sample results or records DO NOT indicate PCB
concentrations ≥50 ppm in one or more “priority materials,” then the screening
assessment is complete. Applicant submits screening form and the supporting
sampling documentation with the demolition permit application. No additional
action is required.
If the representative sample results or records DO indicate PCBs concentrations
≥50 ppm in one or more “priority materials,” then the screening assessment is
complete, but the Applicant MUST also contact applicable State and Federal
Agencies to meet further requirements. Applicant submits screening form and
the supporting sampling documentation with the demolition permit application,
and also must contact the State and Federal Agencies as indicated on Page 3 of
the “PCBs Screening Assessment Form.”
IMPORTANT: ADVANCED APPROVAL FROM THE UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY (USEPA) OR OTHER STATE AGENCIES MAY BE REQUIRED PRIOR TO
BUILDING DEMOLITION. IT IS RECOMMENEDED THAT APPLICANTS BEGIN THE PCBs
ASSESSMENT WELL IN ADVANCE OF APPLYING FOR DEMOLITION PERMIT AS THE
PROCESS CAN TAKE BETWEEN 1-3 MONTHS.
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91. Requirement for oil-water separator in interior parking garage floor drains: If installed,
parking garage floor drains on interior levels shall be connected to an oil-water
separator prior to discharging to the sanitary sewer system. The oil-water separator
shall be cleaned at a frequency of at least once every twelve (12) months or more
frequently if recommended by the manufacturer or required by the Director.
Installation, certification, and maintenance records shall be maintained and made
available for inspection and copying as described in Section 16.09.155 of this Chapter.
Oil-water separators shall have a minimum capacity of 100 gallons (PAMC
16.09.165(a)(8) and 16.09.170(a)(5)).
92. Exemption for requirements below: This requirement can be exempted if no washing is
allowed on-site via rental/lease agreement, any hose bibs are to be fitted with lock-outs
or other connection controls, and signage is posted indicating that car washing is not
allowed (PAMC 16.09.170(a)(6)).
a. Requirement for an oil-water separator for carwash area: A drain shall be
installed to capture all vehicle wash waters and shall be connected to an oil-
water separator prior to discharge to the sanitary sewer system. The oil-water
separator shall be cleaned at a frequency of at least once every
twelve(12)months or more frequently if recommended by the manufacturer or
required by the Director. Oil-water separators shall have a minimum capacity
of100 gallons.
b. Requirement for bermed area around carwash: The area shall be graded or
bermed in such a manner as to prevent the discharge of stormwater to the
sanitary sewer system
93. Discharge drains for pools, spas, and fountains shall not be connected directly to the
storm drain system or to the sanitary sewer system (PAMC 16.09.165(a)(7) and
16.09.170(a)(4)).
Water-Gas-Wastewater Utilities
The following comments are required to be addressed prior to submittal of any future related
permit application such as a Building Permit, Excavation and Grading Permit, Certificate of
Compliance, Street Work Permit, Encroachment Permit, etc. These comments are provided as a
courtesy and are not required to be addressed prior to the Planning entitlement approval:
94. The applicant is to submit flow monitoring data for the sewer connection utility impact
study.
PRIOR TO ISSUANCE OF DEMOLITION PERMIT (if required)
95. The applicant shall submit a request to disconnect utility services and remove meters.
The utilities demo is to be processed within 10 working days after receipt of the request.
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The demolition permit will be issued by the building inspection division after all utility
services and/or meters have been disconnected and removed.
FOR BUILDING PERMIT
96. The Domestic Water meter and service location is to be finalized in the Building Permit.
This includes the Public Utility Easement (P.U.E) for the Water meter. Sizing of meter
and service to be determined in the Building Permit. Water meter is to comply with City
of Palo Alto Utilities Standard Detail WD-04.
97. The Irrigation Meter location is to be finalized in the Building Permit. Service is to be
relocated to connect off the domestic service. Sizing of meter and service to be
determined in the Building Permit.
98. Fire Service location is to be finalized in the Building Permit.
99. Sewer Alignments are to be finalized in the Building Permit.
100. The applicant shall submit a completed water-gas-wastewater service
connection application - load sheet for the City of Palo Alto Utilities. The applicant must
provide all the information requested for utility service demands (water in fixture
units/g.p.m., gas in b.t.u.h, and sewer in fixture units/g.p.d.). The applicant shall provide
the existing (prior) loads, the new loads, and the combined/total loads (the new loads
plus any existing loads to remain).
101. The applicant shall submit improvement plans for utility construction. The plans
must show the size and location of all underground utilities within the development and
the public right of way including meters, backflow preventers, fire service requirements,
sewer mains, sewer cleanouts, sewer lift stations, and any other required utilities. Plans
for new wastewater laterals and mains need to include new wastewater pipe profiles
showing existing potentially conflicting utilities especially storm drain pipes, electric and
communication duct banks. Existing duct banks need to be daylighted by potholing to
the bottom of the duct bank to verify cross section prior to plan approval and starting
lateral installation. Plans for new storm drain mains and laterals need to include profiles
showing existing potential conflicts with sewer, water, and gas.
102. The applicant must show on the site plan the existence of any auxiliary water
supply, (i.e. water well, gray water, recycled water, rain catchment, water storage tank,
etc).
103. The applicant shall be responsible for installing and upgrading the existing utility
mains and/or services, laterals as necessary to handle anticipated peak loads. This
responsibility includes all costs associated with the design and construction for the
installation/upgrade of the utility mains and/or services/laterals. The Developer’s
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financial responsibility for utility upgrades exceeding the impacts of the development
shall be limited to Developer’s fair share contribution, as reasonably determined by the
Utilities Department.
104. An approved reduced pressure principle assembly (RPPA backflow preventer
device) is required for all existing and new water connections from Palo Alto Utilities to
comply with requirements of California administrative code, title 17, sections 7583
through 7605 inclusive. The RPPA shall be installed on the owner's property and directly
behind the water meter within 5 feet of the property line. RPPA's for domestic service
shall be lead free. Show the location of the RPPA on the plans.
105. An approved reduced pressure detector assembly (RPDA backflow preventer
device, STD. WD-12A or STD. WD-12B) is required for all existing and new fire water
connections from Palo Alto Utilities to comply with requirements of California
administrative code, title 17, sections 7583 through 7605 inclusive. The RPDA shall be
installed on the owner's property and directly behind the City owned meter, within 5'
(feet) of the property line or City Right of Way.
106. All backflow preventer devices shall be approved by the WGW engineering
division. Inspection by the city inspector is required for the supply pipe between the
meter and the assembly.
107. The applicant shall pay the capacity fees and connection fees associated with
new utility service/s or added demand on existing services. The approved relocation of
services, meters, hydrants, or other facilities will be performed at the cost of the
person/entity requesting the relocation.
108. If a new water service line installation for fire system usage is required. Show
the location of the new water service on the plans. The applicant shall provide to the
engineering department a copy of the plans for fire system including all fire
department's requirements.
109. Each unit or building shall have its own water meter and gas meter shown on the
plans. Each parcel shall have its own water and gas service and sewer lateral connection
shown on the plans.
110. A sewer lateral per lot is required. Show the location of the new sewer lateral on
the plans. A profile of the sewer lateral is required showing any possible conflicts with
storm, electric/communications ductbanks or other utilities.
111. All existing water, and gas. and wastewater services/laterals that will not be
reused shall be abandoned at the main per the latest WGW utilities standards.
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112. Utility vaults, transformers, utility cabinets, concrete bases, or other structures
cannot be placed over existing water, gas, or wastewater mains/services. Maintain 1'
horizontal clear separation from the vault/cabinet/concrete base to existing utilities as
found in the field. If there is a conflict with existing utilities, Cabinets/vaults/bases shall
be relocated from the plan location as needed to meet field conditions. Trees may not
be planted within 10 feet of existing water, gas, and wastewater mains/laterals/water
services/or meters. New water or wastewater services/laterals/meters may not be
installed within 10' of existing trees. Maintain 10' between new trees and new water
and wastewater services/laterals/meters.
SECTION 8. Conditions of Approval Vesting Tentative Map.
Planning
1. PROJECT PLANS. The Final Map submitted for review and approval by the City Council
shall be in substantial conformance with the Vesting Tentative Map titled “VESTING
TENTATIVE MAP – 3606 EL CAMINO REAL (25PLN-00243)”, prepared by Kier+Wright and
submitted February 3, 2026, except as modified to incorporate the conditions of this
approval.
2. FINAL MAP COVER PAGE. At such time as the Final Map is filed, the cover page shall
include the name and title of the Director of Planning and Development Services.
3. DEVELOPMENT IMPACT FEES. The Property Owner or their designee shall pay all
applicable development impact fees associated with the proposed development and
subdivision prior to issuance of the building permit(s) or recordation of the Final Map, as
detailed in the Major Architectural Review Approval. Impact fees may be paid prior to
occupancy in accordance with the requirements under PAMC 16.64.030 and as
permitted by SB 937, with a lien on the property.
4. IMPACT FEE 90-DAY PROTEST PERIOD. California Government Code Section 66020
provides that a project applicant who desires to protest the fees, dedications,
reservations, or other exactions imposed on a development project must initiate the
protest at the time the development project is approved or conditionally approved or
within ninety (90) days after the date that fees, dedications, reservations or exactions
are imposed on the Project. Additionally, procedural requirements for protesting these
development fees, dedications, reservations and exactions are set forth in Government
Code Section 66020. IF YOU FAIL TO INITIATE A PROTEST WITHIN THE 90-DAY PERIOD
OR FOLLOW THE PROTEST PROCEDURES DESCRIBED IN GOVERNMENT CODE SECTION
66020, YOU WILL BE BARRED FROM CHALLENGING THE VALIDITY OR REASONABLENESS
OF THE FEES, DEDICATIONS, RESERVATIONS, AND EXACTIONS. If these requirements
constitute fees, taxes, assessments, dedications, reservations, or other exactions as
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specified in Government Code Sections 66020(a) or 66021, this is to provide notification that, as
of the date of this notice, the 90-day period has begun in which you may protest these
requirements. This matter is subject to the California Code of Civil Procedures (CCP) Section
1094.5; the time by which judicial review must be sought is governed by CCP Section 1094.6.
Public Works Engineering
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map are subject to City’s technical review and staff approval during the map process
prior to issuance of any construction permits.
10. MAP THIRD-PARTY REVIEW: The City contracts with a third-party surveyor that will
review and provide approval of the map’s technical correctness as the City Surveyor, as
permitted by the Subdivision Map Act. The Public Works Department will forward a
Scope & Fee Letter from the third-party surveyor, and the applicant will be responsible
for payment of the fee’s indicated therein, which is based on the complexity of the map.
11. STREETWORK PERMIT: The applicant shall obtain a Streetwork Permit from the
Department of Public Works for all public improvements.
12. SPECIAL STREET LIGHT: This project is located within an area designated to have special
streetlights as shown in the Special Street Light Style Placement Guide. Any new or
replaced streetlights shall be installed to the standards adopted by the Public Works
Department and Utility Department.
https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development-
services/current-planning/pw-style-placement-guide-2020.pdf
13. UPGRADE OF EXISTING PUBLIC IMPROVEMENTS: As part of the plan review for
improvements within the public right-of-way, any existing improvements to be re-used
by the project, which are not to current City standards and are not specifically in these
project conditions (such as streetlights, utility covers and lids, etc.), shall be upgraded to
current City standards as required by the Director of Public Works and the Director of
Utilities.
14. MODIFICATIONS TO EXISTING PUBLIC UTILITIES: The Developer is responsible for any
changes or modifications to existing utilities, streets, and public infrastructure within or
adjacent to the project site. This includes, but is not limited to, the relocation of utility
facilities, conduits, or vaults required due to grade changes in the sidewalk area
resulting from the development.
15. DAMAGE TO EXISTING PUBLIC IMPROVEMENTS: The Developer is responsible for
repairing any damage to existing public improvements fronting or adjacent to the
project site caused by construction, to the satisfaction of the Public Works Department.
16. EXISTING UTILITY ABANDONMENT AND/OR RELOCATION: The Developer is responsible
for researching all existing utility lines to ensure there are no conflicts with the project.
Any existing utility lines (public or private) or their appurtenances that conflict with the
project or do not serve it must be capped, abandoned, removed, relocated, or disposed
of to the satisfaction of the City.
17. RE-USE OF EXISTING STORM DRAINS: The re-use of existing City storm drain service lines
and appurtenances is subject to City review and approval. The Developer’s contractor
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shall expose the existing storm drain facilities during construction for City inspection or
provide video documentation of their condition. Any deficient facilities, as determined
by Public Works, must be replaced by the Developer.
18. STORM DRAIN TRIBUTARY PATTERN: This project must follow the existing storm drain
tributary pattern. Any deviations require additional analysis and approval by Public
Works during plan review. The project shall not negatively impact the drainage pattern
for adjacent properties.
19. GRADING AND EXCAVATION PERMIT: A Grading Permit is required per PAMC Chapter
16.28. The permit application and all applicable documents (see Section H of
application) shall be submitted to Public Works Engineering. Add the following note:
“THIS GRADING PERMIT WILL ONLY AUTHORIZE GENERAL GRADING AND INSTALLATION
OF THE STORM DRAIN SYSTEM. OTHER BUILDING AND UTILITY IMPROVEMENTS ARE
SHOWN FOR REFERENCE INFORMATION ONLY AND ARE SUBJECT TO SEPARATE
BUILDING PERMIT APPROVAL.”
20. ROUGH GRADING: provide a Rough Grading Plan for the work proposed as part of the
Grading and Excavation Permit application. The Rough Grading Plans shall include the
following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over
excavation, stockpile area of material, overall earthwork volumes (cut and fill),
temporary shoring for any existing facilities, ramps for access, crane locations (if any),
tree protection measures, etc.
21. CIVIL ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the
final completion of the work, applicant shall provide an as-graded grading plan prepared
by the civil engineer that includes original ground surface elevations, as-graded ground
surface elevations, lot drainage patterns and locations and elevations of all surface and
subsurface drainage facilities. The civil engineer shall certify that the work was done in
accordance with the final approved grading plan.
22. DIRECT CONNECTIONS TO STORM DRAIN SYSTEM: If the project proposes to replace
and/or add connections to the City maintained storm drain system, then the applicant
may be responsible for improvements to the system. These improvements may include,
but not limited to, upsizing the storm drain facility, replacing or adding City standard
catch basins, pipes and manholes. THIS MAY INCLUDE REPLACING BRICK AND MORTAR
MANHOLES. The extent of required improvements will be at the public works staff
discretion and shall be consistent with Storm Drain Master Plan and Public Works
Construction Standards. Any work on the city's storm drain systems requires permits
and inspection by Public Works inspectors. The Developer’s financial responsibility for
storm drain facility upgrades exceeding the impacts of the development shall be limited
to Developer’s fair share contribution, as reasonably determined by the Public Works
Department.
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23. CCTV OF STORM DRAIN SYSTEM: Post construction the applicant may be required to
provide CCTV inspection of the City’s storm drain facilities to verify that any lines were
not broken, cracked or damaged during construction. The video shall be high resolution
and done by professional who is familiar with the process and meticulous. A CCTV
inspection video is required for new storm drain connection (s) to verify proper
connections were made into the City’s system and that no construction material was left
behind. Videos of storm drain system may also be required where construction occurred
less than 5-ft from the city’s storm drain system. Videos shall be provided from structure
to structure, such as manhole to manhole. Contractor may want to conduct their own
inspection in advance of construction to verify the existing pipe integrity. If existing
damages are located, they shall be reported to Public Works inspectors prior to the start
of construction. If not reported, the contractor may be responsible to restore the pipe
segment as determined by Public Works prior to final.
24. GEOTECHNICAL ENGINEER STATEMENT: The grading plans shall include the following
statement signed and sealed by the Geotechnical Engineer of Record: “THIS PLAN HAS
BEEN REVIEWED AND FOUND TO BE IN GENERAL CONFORMANCE WITH THE INTENT
AND PURPOSE OF THE GEOTECHNICAL REPORT”.
25. SWPPP: This proposed development will disturb more than one acre of land.
Accordingly, the applicant shall apply for coverage under the State Water Resources
Control Board’s (SWRCB) NPDES general permit for storm water discharge associated
with construction activity. A Notice of Intent (NOI) shall be filed for this project with the
SWRCB in order to obtain coverage under the permit. The General Permit requires the
applicant to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP).
The applicant is required to submit two copies of the NOI and the draft SWPPP to the
Public Works Department for review and approval prior to issuance of the building
permit. The SWPPP should include both permanent, post-development project design
features and temporary measures employed during construction.
26. ENCROACHMENT PERMIT: Prior to any work in the public right-of-way, the applicant
shall obtain an encroachment permit from the Public Works Department for any work
that encroaches onto the City right-of-way.
27. LOGISTICS PLAN: A construction logistics plan shall be provided addressing all impacts
to the public including, at a minimum: work hours, noticing of affected businesses, bus
stop relocations, construction signage, dust control, noise control, storm water pollution
prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane
lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck
routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance,
Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may
require an encroachment permit.
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28. STORMWATER POLLUTION PREVENTION: All improvement plan sets shall include the
“Pollution Prevention – It’s Part of the Plan” sheet.
29. C.3 THIRD-PARTY CERTIFICATION: Applicant shall provide certification from a qualified
third-party reviewer that the proposed permanent storm water pollution prevention
measures comply with the requirements of Provision C.3 and Palo Alto Municipal Code
Chapter 16.11. Submit the following:
a. Provide a stamped and signed C.3 data form (April 2024 version) from
SCVURPPP. https://scvurppp.org/2024/09/19/provision-c-3-data-form-2024/
b. Final stamped and signed letter confirming which documents were reviewed and
that the project complies with Provision C.3 and PAMC 16.11.
30. C.3 STORMWATER AGREEMENT: The applicant shall enter into a Stormwater
Maintenance Agreement with the City to guarantee the ongoing maintenance of the
permanent storm water pollution prevention measures. The City will inspect the
treatment measures yearly and charge an inspection fee. The agreement shall be
executed by the applicant team prior to building permit final.
31. C.3 FINAL THIRD PARTY CERTIFICATION PRIOR TO OCCUPANCY: Within 45 days of the
installation of the required storm water treatment measures and prior to the issuance
of an occupancy permit for the building, the third-party reviewer shall submit to the City
a certification verifying that all the permanent storm water pollution prevention
measures were installed in accordance with the approved plans.
32. PAVEMENT RESTORATION: The applicant shall restore the pavement along the entire
project frontage, curb-to-curb, by performing a 3.5” grind and overlay. The exact
restoration limits will be determined once the resulting road condition is known
following completion of heavy construction activities and utility lateral installations, at
minimum the extent will be the project frontage.
33. EXISTING EASEMENTS: Provide documentation showing approval from the entities
affected by the onsite easements to verify that the work within said easements is
permitted.
34. OUTSIDE AGENCY APPROVAL: A portion of the proposed work is within Caltrans right-of-
way. Evidence of permit approvals shall be submitted prior to issuance of City permits.
35. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (STORM DRAIN LOGO): The applicant is
required to paint “No Dumping/Flows to Matadero Creek” in blue on a white
background adjacent to all onsite storm drain inlets. The name of the creek to which
the proposed development drains can be obtained from Public Works Engineering.
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Stencils of the logo are available from the Public Works Environmental Compliance
Division, which may be contacted at (650) 329-2598. Include the instruction to paint the
logos on the construction grading and drainage plan.
36. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (RECORD DRAWINGS): At the conclusion
of the project applicant shall provide digital as-built/record drawings of all
improvements constructed in the public right-of-way or easements in which the City
owns an interest.
37. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (INDEFINITE ENCROACHMENT PERMIT):
An approved indefinite encroachment permit will be required for any private
infrastructure constructed in the public right-of-way, easement or on property in which
the City holds an interest, but that was not authorized by a building permit.
38. Placeholder Drainage Conditions of Approval Forthcoming.
Water-Gas-Wastewater Utilities
39. On Sheet C4.1 – Preliminary Civil Site Plan, and C6.1 – Preliminary Utility Plan, Water
meter shall be relocated so no obstruction is within the 10x10 easement. Refer to
conditional comment in C7_3606 El Camino Real_Plans for location.
40. On Sheet C4.1 – Preliminary Civil Site Plan, and C6.1 – Preliminary Utility Plan, remove
sewer connection shown on El Camino Real. Refer to conditional comment in C7_3606
El Camino Real_Plans for location. If a secondary sewer connection is needed
connection shall be on Kendal Ave. or Matadero Ave.
41. On Sheet C4.1 – Preliminary Civil Site Plan, and C6.1 – Preliminary Utility Plan, add
Reduced Pressure Principal Assembly (RPPA) to irrigation service per CPAU WGW
Standard WD-11C
SECTION 9. Term of Approval.
1. Architectural Review Application. In the event actual construction of the project is
not commenced within two years of the Effective Date, the approval shall expire and be
of no further force or effect. An extension may be granted in accordance with the
allowances set forth in the municipal code and state law.
2. Vesting Tentative Map. All conditions of approval of the Vesting Tentative Map shall be
fulfilled prior to approval of a Final Map (PAMC Section 21.16.010[c]). Unless a Final
Map is filed, and all conditions of approval are fulfilled within a two-year period from
the date of Vesting Tentative Map approval, the Vesting Tentative Map shall expire and
all proceedings shall terminate. A request for an extension of time may be granted by
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the city council after recommendation of the planning commission, after the written
extension request of the subdivider is submitted, prior to the expiration of the Vesting
Tentative Map approval, or any previous extension granted. Such extension(s) shall be
subject to the maximum limitations set forth in the Subdivision Map Act.
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INTRODUCED AND PASSED:
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ATTACHMENT C
3606 El Camino Real, 24PLN-00161
Table 1: COMPARISON WITH CHAPTER 18.14 (Housing Incentives) El Camino Real Focus Area
for CS DISTRICT (18.16) PARCELS
Residential Development Standards (APNs: 137-08-088, -016, and -079)
Regulation Required Proposed
Minimum Site Area, width and
depth
None No change
Minimum Front Yard
(El Camino Real)
0-10 feet to create a 12 foot
effective sidewalk width (1), (2), (8)
9 feet 11 inches
2 feet 6 inches foot Public Access
Easement on El Camino Real – to
create an effective 12-foot sidewalk
Rear Yard 10 feet for residential portion 11 feet – 15 feet
Interior Side Yard 10 feet adjacent to residential uses Not Applicable
Street Side Yard
(Matadero Avenue)
5 feet 11 feet – 15 feet
Build-to-lines 50% of frontage built to setback on
El Camino Real
33% of side street built to setback on
Matadero Avenue (7)
90% of frontage built to setbacks
Upper Story Step Back El Camino Real frontage above 55
feet in height: minimum 10 foot
step-back from lower facade, for a
minimum 70% of the facade length.
Not proposed
Max. Site Coverage 50%
80%* (ECR Focus Area Allowance)
83%
Max. Building Height 35 ft
85* ft (ECR Focus Area Allowance)
85 ft
Daylight Plane for lot lines abutting
one or more residential zoning
districts
None Complies
Max. Floor Area Ratio (FAR)0.6:1
4.0* (ECR Focus Area Allowance)
3.31:1 (86,595 sf of 26,149 sf lot
size)
Max. Residential Density 108 DU/AC with 24.5% bonus
(Cal. Gov. Code 65589.5(h)(11)(C))
128 du/acre
Minimum Usable Open Space 100 sf per unit (5,700 sf) (ECR Focus
Area Allowance)
8,0019 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.
(7) 25 foot driveway access permitted regardless of frontage, build-to requirement does not apply to CC district.
(8) A 12 foot sidewalk width is required along El Camino Real frontage
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Table 2: COMPARISON WITH CHAPTER 18.14 (HOUSING INCENTIVES) EL CAMINO REAL FOCUS AREA
FOR CN DISTRICT (18.16) PARCELS
Mixed-use and Residential Development Standards
Regulation Required Proposed
Minimum Site Area, width and
depth
None No change
Minimum Front Yard
(El Camino Real)
0-10 feet to create an 8-12 foot
effective sidewalk width (1), (2), (8)
9 feet 11 inches
2 feet 6 inches foot Public Access
Easement on El Camino Real – to
create an effective 12-foot
sidewalk
Rear Yard None Not Applicable
Interior Side Yard None Not Applicable
Street Side Yard (Kendall Avenue)20 feet (2)
5* ft (ECR Focus Area Allowance)
11 feet – 15 feet
Min. yard for lot lines abutting or
opposite residential districts or
residential PC districts
10 feet (2)10 feet – 26 feet
Build-to-lines 50% of frontage built to setback on
El Camino Real
33% of side street built to setback
on Kendall Avenue (7)
90% of frontage built to setbacks
Max. Site Coverage 50%
80%* (ECR Focus Area Allowance)
83%
Max. Building Height 25 ft and 2 stories
85* ft (ECR Focus Area Allowance)
85 ft
Max. Floor Area Ratio (FAR)0.5:1
4.0* (ECR Focus Area Allowance)
3.81:1 (169,379 sf of 44,495 sf lot
size)
Daylight Plane for lot lines abutting
one or more residential zone
districts
None (6)Complies (Abutting RM-40)
Minimum Usable Open Space 100 sf per unit (12,000 sf) (ECR Focus
Area Allowance)
12,940 sf
Max. Residential Density 108 DU/AC with 24.5% bonus
(Cal. Gov. Code 65589.5(h)(11)(C))
128 du/acre
(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.
(7) 25 foot driveway access permitted regardless of frontage, build-to requirement does not apply to CC district.
(8) A 12 foot sidewalk width is required along El Camino Real frontage
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Table 3: COMPARISON WITH CHAPTER 18.14 (HOUSING INCENTIVES) EL CAMINO REAL FOCUS AREA
FOR RM-30 DISTRICT (18.13)
Regulation Required Proposed
Minimum/Maximum Site Area,
Width and Depth
8,500 sf area, 70 foot width, 100
foot depth
No Change
Minimum Front Yard
(Kendall Avenue)
(2) 20 feet 9 feet
Rear Yard 10 feet 11 feet -15 feet
Interior Side Yard 6 feet 6 feet
Street Side Yard 16 feet Not Applicable
Setback from major roadways
[18.13.040(b)(1)(A)]
25 feet Not Applicable
Max. Building Height 35 feet
85* ft (ECR Focus Area Allowance)
85 feet
Side Yard Daylight Plane None Not Applicable
Rear Yard Daylight Plane None Not Applicable
Max. Site Coverage 40%
80% (ECR Focus Area Allowance)
83%
Max. Total Floor Area Ratio 0.6:1
4.0* (ECR Focus Area Allowance)
3.39:1
Minimum Site Open Space 30% 17%
Minimum Usable Open Space 150 sf per unit (18,000 sf)
100 sf per unit (12,000 sf) (ECR Focus
Area Allowance)
0 sf
Minimum Common Open Space 75 sf per unit (9,000 sf)0 sf
Minimum Private Open Space 50 sf per unit (6,000 sf)2,447 sf
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Table 4: COMPARISON WITH CHAPTER 18.14 (HOUSING INCENTIVES) EL CAMINO REAL FOCUS AREA
FOR RM-40 DISTRICT (18.13)
Regulation Required Proposed
Minimum/Maximum Site Area,
Width and Depth
8,500 sf area, 70 foot width, 100
foot depth
No Change
Minimum Front Yard
(Kendall Avenue)
(2) 0-25 feet (1) 9 feet
Rear Yard 10 feet Not Applicable
Interior Side Yard 10 feet, 6 feet for properties less
than 70 feet wide
11 feet – 15 feet
Street Side Yard 0-16 feet (2)Not Applicable
Setback from major roadways (1)
[18.13.040(b)(1)(A)]
0-25 feet (1)Not Applicable
Max. Building Height 40 feet
85* ft (ECR Focus Area Allowance)
85 feet
Side Yard Daylight Plane (7)10 feet at interior side lot line then
45 degree angle
Does not comply
Rear Yard Daylight Plane (7)10 feet at rear setback line then 45
degree angle. None for lots > than
70 ft wide
Does not comply
Max. Site Coverage 45%, plus 5% for covered patios
80% (ECR Focus Area Allowance)
83%
Max. Total Floor Area Ratio (4)1.0:1
4.0* (ECR Focus Area Allowance)
2.43:1
Max. Residential Density (3) 40 DU/AC
108 DU/AC with 24.5% bonus
(Cal. Gov. Code 65589.5(h)(11)(C))
128 du/ac
Minimum Site Open Space 20% 17%
Minimum Usable Open Space (5)100 sf per unit (1,500 sf)0 sf
Minimum Common Open Space 50 sf per unit (750 sf) 347 sf
Minimum Private Open Space 50 sf per unit (750 sf)1,034 sf
(1) Minimum front setbacks shall be determined by the Architectural Review Board upon review pursuant to criteria
set forth in Chapter 18.76 and the context-based criteria outlined in Section 18.13.060. Arterial roadways do not
include residential arterials.
(2) Minimum street side setbacks in the RM-40 zone may be from 0 to 16 feet and shall be determined by the
Architectural Review Board upon review pursuant to criteria set forth in Chapter 18.76 and the context-based
criteria outlined in Section 18.13.060.
(3) Provided that, for any lot of 5,000 square feet or greater, two units are allowed, subject to compliance with all other
development regulations.
(4) Covered parking is not included as floor area in multi-family development, up to a maximum of 230 square feet per
required parking space. Covered parking spaces in excess of required parking spaces count as floor area.
(5) Subject to the limitations of Section 18.13.040(e). Usable open space is included as part of the minimum site open
space; required usable open space in excess of the minimum required for common and private open space may be
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used as either common or private usable open space; landscaping may count towards total site open space after
usable open space requirements are met.
(6) Tandem parking is allowed for any unit requiring two parking spaces, provided that both spaces in tandem are
intended for use by the same residential unit. For projects with more than four (4) units, not more than 25% of the
required parking spaces shall be in a tandem configuration.
(7) Each daylight plane applies specifically and separately to each property line according to the adjacent use.
18.16.090 Context-Based Design Criteria. As further described in a separate attachment, development in a
commercial district shall be responsible to its context and compatible with adjacent development, and shall
promote the establishment of pedestrian oriented design.
Table 5: CONFORMANCE WITH CHAPTER 18.52 (Off-Street Parking and Loading)
for Multiple Family Residential*
Type Required Proposed
Vehicle Parking 1 per unit (321 units) = 321 spaces
(ECR Focus Area Allowance)
391 spaces, 90 tandem, 7 guest
parking
Bicycle Parking 1 per unit long term (321)
1 per 10 units short term (32)
280 long term
12 short term
Loading Space 1 required for more than 50 units 0 provided
City of Palo Alto - Objective Design Standards Checklist
Page 1
Objective Design Standards Checklist
The Objective Design Standards Checklist is a tool to evaluate a project’s compliance with the Zoning Ordinance (Chapter 18.24). The Checklist is
not the Zoning Ordinance. Applicants shall be responsible for meeting the standards in the Zoning Ordinance. To simplify evaluation of the
Zoning Ordinance, language in the Checklist may vary from the Zoning Ordinance. (Note: sf = square feet)
If a standard is not applicable to applicant’s project, please write N/A in Applicant’s Justification column.
18.24.020 Public Realm/Sidewalk Character
Check Standard Sheet #Notes
(b)(1) Sidewalk Widths
(A) In the following districts, public sidewalk width (curb to back of walk) is at least:
Commercial Mixed-Use District: CN, CS, CC, CC(2), CD-C, CD-S, CD-N, PTOD: 10 ft
El Camino Real: 12 ft
San Antonio Road, from Middlefield Road to East Charleston Road: 12 ft
And consists of:
AP1.00
Complies.
2 feet 6 inches foot Public
Access Easement on El Camino
Real – to create an effective 12-
foot sidewalk
Pedestrian clear path width of 8 foot minimum: 12 feet
☐
Landscape or furniture area width of 2 foot minimum: 11.5 feet
☐
If the existing public sidewalk does not meet the minimum standard, a
publicly accessible extension of the sidewalk, with corresponding public
access easement, shall be provided.
☐
(B) Public sidewalks or walkways connecting through a development parcel (e.g. on a
through lot with a public access easement, leading to a commercial entry) must
be at least 6 feet wide.
(C) The width of walkways designed to provide bicycle access (e.g. pathway to bike
racks/lockers) must be at least 12 feet wide, consisting of: AP1.00
Complies.
2 feet 6 inches foot Public
Access Easement on El Camino
Real – to create an effective 12-
foot sidewalk
☒
Pedestrian clear path width (8 feet min.): 8 ft
City of Palo Alto - Objective Design Standards Checklist
Page 2
Clear space/buffer – (2 feet min. on each side of path, ground cover is
allowed): 11.5 feet and 4 feet
Check Standard Sheet #Applicant’s Justification
(B)(2) Street Trees
1. One street tree provided for every 30 linear feet of public sidewalk length and
located within six feet of the sidewalk. L2.1 Complies
a. Length of parcel frontage/public sidewalk length: 412 feet
b. Street Trees required (i.e. frontage/30 feet): 14 trees
☒
c. Street Trees provided: 17 (5 existing + 12 new)
(B)(3) Accent Paving
Parcels abutting University Avenue between Alma Street and Webster include accent
paving along the project frontages, as indicated below: N/A
Brick paving at corners ☐
Brick trim mid-block
☐Parcel abutting California Avenue between El Camino Real and Park Blvd include
decorative glass accent paving along project frontages
(B)(4) Mobility Infrastructure
☒
(A) On-site micromobility infrastructure (e.g. bike racks/lockers) is located within
30 feet of the primary building entry and/or on a path leading to the primary
building entry; OR
AP2.01 Complies
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☐Existing micromobility infrastructure (e.g. bike racks/lockers) is already
located within 50 feet of project site and located in a public right-of-way.
Pi
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(B) Primary building entries shall provide at least one seating area or bench
within 30 feet of building entry and/or path leading to building entry. On
arterials (see Map T-5), except Downtown, seating areas or benches shall not
be located between the sidewalk and the curb; OR
AP2.01 Complies
City of Palo Alto - Objective Design Standards Checklist
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☐Existing seating areas or benches that are already located in the public right-of-way
within 50 feet of the building entry.
18.24.030 Site Access
Check Standard Sheet #Applicant’s Justification
(b)(1) Through Lot Connections
☐
Through lots located more than 300 feet from an intersecting street or pedestrian
walkway shall provide a publicly accessible sidewalk or pedestrian walkway (with
public access easements) connecting the two streets.
N/A
(b)(2) Building Entries
☒
Primary Building Entries shall be located from a public right-of-way. If there is no
public right-of-way adjacent to the building, entries shall be located from a private
street or Pedestrian Walkway.
AP2.01 Complies
(b)(3) Vehicle Access
☒(A) Vehicle access shall be located on alleys or side streets when they abut the
property.AP2.01 Complies
☒
(B) Except for driveway access and short-term loading spaces (e.g. taxi), off-street
parking, off-street vehicle loading (delivery trucks), and vehicular circulation areas
are prohibited between the building and primary building frontage.
AP2.01 Complies
(b)(4) Loading Docks and Service Areas
Loading and service areas shall be integrated into building and landscape design and located to
minimize impact on the pedestrian experience as follows:AP2.01 Loading provided.
☐(A) Loading docks and service areas shall be located on façades that do not face a
primary building frontage
☐
(B) Loading docks and service areas located within setback areas shall be
screened by a solid fence, or wall, or dense landscaping and separated from
pedestrian access to the primary building entry to avoid impeding pedestrian
movement/safety.
City of Palo Alto - Objective Design Standards Checklist
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18.24.040 Building Orientation and Setbacks
Check Standard Sheet #Applicant’s Justification
(b)(1) Building Corner Elements (less than 40 feet in height)
Corner buildings less than 40 feet in height and end units of townhouses or other attached housing products that face the street shall include
all of the following features on their secondary building frontage:
(A) height and width of corner element shall have a ratio greater than 1.2:1. For
townhomes, the width would be equal to the smaller side of one unit?Building above 40 feet
a. Secondary building frontage height: _____ feet
b. Secondary building frontage length: _____ feet
☐
c. Secondary building frontage height to width ratio: ___
(B) minimum of 15% fenestration area.
a. Total secondary building frontage façade area: ___ sf
b. Secondary building frontage façade fenestration area: ___ sf☐
c. Percent of fenestration area _____ %
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☐(C) At least one facade modulation with a minimum depth of 18 inches and a
minimum width of two feet.
(b)(2)(A) & (B) Treatment of Buildings Corners on Corner Lots (40+ feet in height)
Corner Buildings 40 feet or taller in height shall include at least one of the following special features:
A. Street wall is located at the minimum front yard setback or build-to line for a minimum
aggregated length of 40 feet on both facades meeting at the corner and includes one or
more of the following building features:
☒i. An entry to ground floor retail or primary building entrance located within
25 feet of the corner of the building.AP3.00 Complies
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☒ii. A different material application and/or fenestration pattern from the rest of
the façade.AP3.00 Complies
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☐iii. A change in height of at least 4 feet greater or less than the height of the
adjacent/abutting primary façade.
B. An open space with a minimum dimension of 20 feet and minimum area of 450 sf. The
open space shall be at least one of the following
☐i. A publicly accessible open space/plaza.
☐ii. A space used for outdoor seating for public dining.
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iii. A residential Common Open Space adjacent to a common interior space
(i.e. lobby, retail, etc.) and less than two feet above adjacent sidewalk grade.
Fences and railing shall be a minimum 50% open/transparent.
(b)(3) Primary Building Entry
The primary building entry meets at least one of the following standards:
☒A. Faces a public right-of-way.AP3.00
☒B. Faces a publicly accessible pedestrian walkway.AP3.00 Complies
C. Is visible from a public right-of-way through a forecourt or front porch that
meets the following standards:
i. For residential buildings with fewer than seven units, building entry
forecourts or front porch minimum dimensions of (min. 36 sf and min.
dimension of 6 feet required): ___ sf and ___ ft. min. dimension
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☐ii. For commercial buildings or residential buildings with seven or
more units, building entry forecourts or front porch minimum
dimensions of (min. 100 sf and a min. width of 8 feet required): ___ sf
and ___ ft. min. width
(b)(4) Ground Floor Residential Units
A. Finished Floor Height for Ground Floor Units
☐
The finished floor of ground floor residential units, when adjacent to a public right-of-
way, must be within the minimum and maximum heights according to setback distance
from back of walk identified in Figure 2a and 2b of the Zoning Ordinance. Calculate
minimum ground floor finished floor height: AP2.01 No ground floor units
City of Palo Alto - Objective Design Standards Checklist
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City of Palo Alto - Objective Design Standards Checklist
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☐Setback adjacent to public right of way: 20 feet
☐
Minimum ground floor finished floor height: ___0__ feet
𝒚 = ―
𝟒
𝟏𝟓(𝒙)+ 𝟏𝟔
𝟑 where 𝑥 = setback length from back of walk, in feet
and 𝑦 = ground floor finished floor height, in feet
☐Sites with slopes greater than 2% along building façade – Average height of
finished floor: _____ feet
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☒Sites located in flood zones – the minimum ground floor finished floor height
shall be defined by FEMA, less flood zone elevation: _11____ feet
B. Setback Trees
Ground floor units with a setback greater than 15 feet must have at minimum an
average of one tree per 40 linear feet of facade length, within the setback area. AP2.01 No ground floor units
Facade length:
Trees required: tree(s) (i.e. façade length / 40)
☐
Trees provided: tree(s)
C and D. Front Setback
☐C. Ground floor residential entries are setback a minimum of 10 feet from the
back of public sidewalk; OR AP2.01 No ground floor units
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D. Where no minimum building setback is required, all ground floor residential
units must be set back a minimum 5 feet from back of public sidewalk.
City of Palo Alto - Objective Design Standards Checklist
Page 7
Check Standard Sheet #Applicant’s Justification
E. Unit Entry
A minimum 80% of ground floor residential units that face a public right-of-way or
publicly accessible path, or open space shall have a unit entry with direct access to the
sidewalk, path, or open space for minimum.
AP2.01 No ground floor units
a. Total number of ground floor residential units facing a public right-of-way,
publicly accessible path, or open space: 145 units
b. 80% of total units in (a): 116 units
☐
c. Subset of number of units in (a) that have a unit entry with direct access to the
sidewalk, path, or open space: 145 entries
(b)(5) Front Yard Setback Character
Required setbacks provide a hardscape and/or landscaped area to create a transition between
public and private space. The following standards apply, based on intended use and exclusive of
areas devoted to outdoor seating, front porches, door swing of building entries, and publicly
accessible open space and meet the following:
(A). Ground-floor retail or retail like uses have a minimum of 10% of the required
setback as landscape or planters.N/A
i. Minimum setback area (setback x frontage x 10%): ____ sf☐
ii. Landscape or planter area in required setback: ____ sf
(B). Ground-floor residential uses have a minimum of 60% landscaped area in the
required setback area.
i. Minimum setback area (setback x frontage x 60%):
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ii. Landscape area in required setback:
(b)(6) Side Yard Setback Character
☐
(A) Each detached dwelling unit shall have at least one usable side yard, at least six feet
wide, between the house and fence or other structure, to provide outdoor passage
between the front and rear yards.
N/A
City of Palo Alto - Objective Design Standards Checklist
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City of Palo Alto - Objective Design Standards Checklist
Page 8
18.24.050 Building Massing
Check Standard Sheet #Notes
(b)(1) Upper Floor Step Backs and Daylight Planes
(A) When the height of the subject building is more than 20 feet above the
average height (i.e. average of low and high roof elevations) of an adjacent
building(s), an upper floor step back shall start within two vertical feet of the
average height of the adjacent building. The step back shall be a minimum depth
of six feet along both the façade on the primary building frontage and the façade
facing the adjacent building, and the step shall occur for a minimum of 70% of
each façade length.
AP3.21
Stepbacks occur on floor three
(24 feet). However, in some
locations the full 6 feet in depth
is not provided, in others more
than the 6 feet stepback is
provided.
i. Proposed building height: 85 feet
ii. Average building height of the adjacent building(s): 33.75 feet
☒
iii. Building height where upper floor step back begins: 24 feet
☐(B) Notwithstanding, subsection (A), when adjacent to a single-story building, the
upper floor step back shall occur between 33 and 37 feet in height.
☒
(C) If a project meets the following criteria, a daylight plane with an initial height
of 25 feet above grade at the property line and a 45-degree angle shall be
required. This daylight plane is required if all of these criteria are met:
i. The project is not subject to a daylight plane requirement, pursuant to
district regulations in Title 18; and
ii. The project proposes a building which is more than 20 feet above the
average height (i.e., average of low and high roof elevations) of an
adjacent building(s); and
iii. The project abuts residential units in the side or rear yard.
AP3.01
AP3.02
AP3.03
The building does not comply
with daylight planes.
(b)(2) Privacy and Transitions to Residential Uses
When a building abuts a residential use on an interior side and/or rear property line, the building
shall break down the abutting façade and maintain privacy by meeting all of the following:
City of Palo Alto - Objective Design Standards Checklist
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☒(A) Landscape Screening. A landscape screen that includes a row of trees with a
minimum one tree per 25 linear feet and continuous shrubbery planting. This
screening plant material shall be a minimum 72 inches (6 feet) in height when
planted. Required trees shall be minimum 24” box size.
AP2.01 Complies
☒(B) Façade Breaks. A minimum façade break of 4 feet in width, 2 feet in depth,
and 32 sf of area (i.e. 8 ft tall minimum) for every 36 to 40 feet of façade length
AP3.01
AP3.02
AP3.03
Does not comply. While the
project provides some façade
breaks, the proposed facades
breaks do not meet the
minimum requirements for a
breaks.
☒
(C) Maximum Amount of Transparent Windows. Within 40 feet of an abutting
structure, no more than 15% of the facing façade area shall be windows or other
glazing. Additional windows are allowed in order to maintain light, if fixed and
fully obscured
AP3.01
AP3.02
AP3.03
Complies
(D) Windows. Within 30 feet of facing residential windows (except garage or
common space windows) or private open space on an adjacent residential
building, facing windows on the subject site shall meet the following:
(i) Window sills at and above the 2nd floor shall be at least five feet above
finished floor; or
(ii) Windows shall have opaque or translucent glazing at or below five feet
above finished floor; or
(iii) Windows shall be angled up to 30 degrees (parallel to window) to face
away from the adjacent privacy impacts; and
(iv) Landscape screening shall be 24-inch box size or larger and eight+ feet
height at planting; 50% evergreens; and located to align with proposed
second floor windows at maturity.
AP3.01
AP3.02
AP3.03
Complies
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(E). Balconies: Within 30 feet of residential windows (except garage or common
space windows) or private open space on an adjacent residential building,
balconies and decks on the subject site shall be designed to prevent views:
(i) No sight lines to the adjacent property window or open space are
permitted within five feet above the balcony or deck flooring and a 45-
degree angle downward from balcony railing.
(ii) Submit section view of proposed balcony/deck and abutting residential
windows and/or private open space.
(iii) Provide balcony/deck design measure which may include:
AP3.01
AP3.02
AP3.03
Complies
City of Palo Alto - Objective Design Standards Checklist
Page 10
a. Minimum 85% solid railing
b. Obscure glass railing
c. Barrier with min. 18" horizontal depth from railing (e.g. planter)
(b)(3)(A) & (B) Maximum Façade Length - facing a street or public path
Buildings 70 feet in length or greater and greater than 25 feet in height
For building facades 70 feet in length or greater and facing a public street, right-
of-way, or publicly accessible path shall not have a continuous façade plane
greater than 70% of the façade length without an upper floor modulation, of at
least 2 feet in depth
Largest façade length featuring continuous plane: 61 feet
Total Façade length: 390 feet
☒
Percent of façade length without upper floor modulation (a/b) (maximum
70%): 15 %
Buildings 250 feet in length or greater
(A) Buildings 250 feet in length or greater, which face a public street, right-of-
way, or publicly accessible path, shall have at least one vertical façade break
with a minimum area greater than 400 sf and a width greater than or equal to
two times the depth
AP2.03
AP2.04
AP2.05
AP2.06
AP2.07
Does not Comply
Total Building length: 391 feet
☐
Number of vertical façade breaks: 5 breaks
Width: 42 feet, Depth: 8 feet, Area: 336 sf
Buildings between 150 feet and 250 feet in length
(B) Buildings 150 to 250 feet in length, which face a public street, right-of-way, or
publicly accessible path, shall have at least one vertical façade break with a
minimum area greater than 64 sf and a minimum width of 8 feet and
minimum depth of 4 feet.
Total Building length:
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Number of vertical façade breaks:
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Width:
Check Standard Sheet #Applicant’s Justification
(b)(4) Special Conditions: Railroad Frontages
All parcels with lot lines abutting railroad rights-of-way shall meet the following standards on the
railroad-abutting façade(s):N/A
☐(A) A minimum facade break of at least 10 feet in width and six feet in depth for
every 60 feet of façade length.
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☐(B) For portions of a building 20 feet or greater in height shall not have a
continuous façade length that exceeds 60 feet.
(b)(5) Diversity of Housing Types
☒
A diversity of housing types (e.g. detached units, attached
rowhouses/townhouses, condominiums or apartments, mixed use) are
required for projects on large lots:
Less than one acre lots: minimum 1 housing types
1 to 2-acre lots: minimum 2 housing types; or
More than 2-acre lots: minimum 3 housing types
Does not Comply. 2.6 acre lot
with only residential and
residential accessory uses
proposed.
18.24.060 Façade Design
Check
Two or
More
Standard Sheet #Applicant’s Justification
(c)(1) Base-Middle-Top
☒
Buildings three stories or taller and on lots wider than 50 feet shall be designed to differentiate a defined base or ground floor, a
middle or body, and a top, cornice, or parapet cap. Each of these elements shall be distinguished from one another for a minimum of
80% of the façade length through use of three or more of the following four techniques:
☐
i. Variation in Building Modulation: Building modulation shall extend for a minimum 80%
of the façade length feet, and shall include one or more of the following building
features.
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City of Palo Alto - Objective Design Standards Checklist
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☒a. Horizontal shifts. Changes in floor plates that protrude and/or recess with a
minimum dimension of 2 feet from the primary facade.
AP2.02
AP2.03 Complies
☐
b. Upper floor step backs. A horizontal step back of upper-floor façades with a
minimum 5 foot stepback from the primary façade for a minimum of 80% of
the length of the façade
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c. Ground floor step back. A horizontal shift of the ground floor facade with a
minimum depth of 2 feet for a minimum 80% of the length of the façade.
Ground floor step backs shall not exceed the maximum setback, where stated
☒ii. Variation in Façade Articulation: Façade articulation modulation shall include one or
more of the following building features.Complies
☒
a. Horizontal and/or Vertical Recesses or Projections. Recesses or projections
such as a pattern of recessed grouping of windows, recessed panels, bay
windows or similar strategies. The recess or projection shall be a minimum 4
inches in depth.
AP3.00
AP3.01
AP3.02
AP3.03
☒
b. Horizontal and/or Vertical Projections. Projections such as shading,
weather protection devices, decorative architectural details, or similar
strategies.
AP3.00
AP3.01
AP3.02
AP3.03
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c. Datum Lines. Datum lines that continue the length of the building, such as
parapets or cornices, with a minimum 4 inches in height or a minimum 2
inches in depth and include a change in material
☒iii. Variation in two of the following:
AP3.00
AP3.01
AP3.02
AP3.03
Complies
☒a. Fenestration Size
☒b. Fenestration Proportion
☒c. Fenestration Pattern
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☐d. Fenestration Depth or Projection
☒iv. Variation in two of the following:AP3.00
AP3.01 Complies
City of Palo Alto - Objective Design Standards Checklist
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AP3.02
AP3.03
☒a. Façade Material
☒b. Facade Material Size
☐c. Façade Texture and Pattern
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☒d. Façade Color
(c)(2) Façade Composition
Building facades shall use a variety of strategies including building modulation, fenestration, and façade articulation to create visual interest and
express a variety of scales through a variety of strategies. All facades shall include a minimum of three of the following façade articulation
strategies to create visual interest:
☒A. Vertical and horizontal recesses such as a pattern of recessed grouping of windows or
recessed panels. The recess shall be a minimum 4 inches in depth.
AP3.00
AP3.01
AP3.02
AP3.03
Complies
☒B. Vertical and horizontal projections such as shading and weather protection devices or
decorative architectural details. Projections shall be a minimum 4 inches in depth.
☒
C. Datum lines that continue the length of the building, such as cornices, with a
minimum 4 inches in depth, or a minimum 2 inches in depth and include a change in
material.
☒D. Balconies, habitable projections, or Juliet balconies (every 20 to 40 feet) with a
minimum 4 inches in depth.
☒E. Screening devices such as lattices, louvers, shading devices, or perforated metal
screens.
☐F. Use of fine-grained building materials, such as brick or wood shingles, not to exceed 8
inches in either height or width.
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☒G. Incorporate a minimum of three colors, materials, and/or textures across the whole
building.
(c)(3) Compatible Rhythm and Pattern
City of Palo Alto - Objective Design Standards Checklist
Page 14
(A) Buildings shall express a vertical rhythm and pattern that reflects the size and scale of a housing unit and/or individual rooms and spaces.
This may be achieved with building modulation to create vertically oriented façades (height greater than the width of the façade), façade
articulation and fenestration repetitive vertically oriented patterns. Depending on the length of the façade, the following standards apply:
☐
i. For continuous façades less than 100 feet in length, the façade shall have vertically
oriented patterns of vertical recesses or projections, façade articulation, and/or
fenestration.
ii. For continuous façades 100 feet or greater in length, the façade shall include either:
☒
a. A vertical recess or change in façade plane with a minimum 2 feet deep vertical
shift modulation for a minimum 4 feet in width to establish a vertical rhythm
between 20 to 50 feet in width; OR
AP3.00
AP3.01
AP3.02
AP3.03
Complies
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☐b. A vertical recess or projection with a minimum depth of 2 feet that establishes
the vertical rhythm between 10 to 16 feet in width
(B) Residential mixed-use buildings
☐i. Vertical Patterns and Modulation: Façades shall use vertical patterns of building
modulation, façade articulation, and fenestration.
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ii. Horizontal Patterns and Modulation: Façades that use horizontal articulation and
fenestration patterns shall use a vertical massing strategy with a minimum 4 feet
wide and 2 feet deep vertical shift in modulation at least once every 50 feet of
façade length.
(C) Storefronts
☐Storefront uses must express a vertical rhythm not to exceed 30 to 50 feet in width.
(c)(4) Emphasize Building Elements & Massing
(A)(i) Building Entries within Façade Design. Primary building entries shall be scaled proportionally to
the number of people served (amount of floor-area or number of units accessed). Building entries
shall meet the following minimum dimensions:
☐a. Individual residential entries:
☒b. Shared residential entry, such as mixed-use buildings: AP3.00
AP3.01 Complies
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☐c. Commercial building entry:
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Page 15
☐d. Storefront entry:
(ii) Primary building entries (not inclusive of individual residential entries) shall include a façade
modulation that includes at least one of the following:
☐a. Recess or projection from the primary façade plane (minimum 2 feet).
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☒b. Weather protection that is a minimum 4 feet wide and 4 feet deep by recessing
the entry, providing an awning or using a combination of these methods
AP3.00
AP3.01 Complies
(c)(5) Storefront/Retail Ground Floors
A. Ground floor height shall be a minimum 14 feet floor-to-floor OR shall maintain a 2nd
floor datum line of an abutting building.
AP3.00
AP3.01 Complies
a. Ground floor height (minimum 14 feet): 15 feet; OR☒
b. Height of 2nd floor datum line of abutting building:
B. Transparency shall include a minimum 60% transparent glazing between 2 and 10 feet in
height from sidewalk, providing unobstructed views into the commercial space.
a. Façade area between 2 feet and 10 feet:
b. Transparent glazing area between 2 feet and 10 feet:
☐
c. Percentage of transparent glazing (minimum 60%):
☐C. If provided, bulkheads and solid base walls measure between 12 and 30 inches from
finished grade
D. Primary entries shall include weather protection by recessing the entry, providing an
awning or using a combination of these methods.
a. Weather protection width (minimum 6 feet): 20 feet AP3.00
AP3.01 Complies☒
b. Weather protection depth (minimum 4 feet): 4 feet AP3.00
AP3.01
☐
E. Awnings, canopies and weather protection: (i) When transom windows are above
display windows, awnings, canopies and similar, weather protection elements shall be
installed between transom and display windows. These elements should allow for light to
enter the storefront through the transom windows and allow the weather protection
feature to shade the display window. (ii) Awnings may be fixed or retractable
AP3.00
AP3.01 Complies
(c)(6) Other Non-Residential Ground Floors
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☐(A) Ground floor height must be a minimum 14 feet floor-to-floor OR match the 2nd floor
datum line of an abutting building N/A
☐Ground floor height (minimum 14 feet): _____ feet; OR
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(B) Minimum of 50% transparent glazing between 4 and 10 feet in height from sidewalk or
terrace grade, providing unobstructed views into the commercial space
Façade area between 2 feet and 10 feet:
Transparent glazing area:
☐
Percentage of transparent glazing (minimum 50%):
(C) Primary entries include weather protection that is a minimum 6 feet wide and 4 feet
deep by recessing the entry, providing an awning or using a combination of these methods.
Weather protection width (minimum 6 feet): ☐
Weather protection depth (minimum 4 feet):
(c)(7) Parking/Loading/Utilities
(A) Entry Size
No more than 25% of the site frontage facing a street shall be devoted to garage openings,
carports, surface parking, loading entries, or utilities access. On sites with less than 100
feet of frontage, no more than 25 feet.
AP3.00
AP3.01 Complies
Site frontage: 128 feet Matadero / 240 feet Kendall
Frontage devoted to garage openings, carports, surface parking, loading entries, or
utilities access: 14% Matadero / 8% Kendall
☒
Percent of frontage devoted to garage openings, carports, surface parking, loading
entries, or utilities access 10.7% and 83%
(B) Above Ground Structured Parking
☒
Above grade structured parking levels facing a public right-of-way or publicly accessible
open space/path, with the exception of vehicular alleys, must be lined with commercial or
habitable uses with a minimum depth of 20 feet
AP3.01
AP3.02 Does not comply
(C)&(D) Partially Sub-Grade Structured Parking
City of Palo Alto - Objective Design Standards Checklist
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☐Partially sub-grade parking must not have an exposed façade that exceeds 5 feet in height
above abutting grade at back of sidewalk. N/A
☐Partially sub-grade parking must be screened with continuous landscaping and shrubbery
with minimum height of 3 feet and be located within 10 feet of the sub-grade parking.
18.24.080 Open Space
Check Standard Sheet #Applicant’s Justification
(b)(1) Private Open Space
☒
(A) Floor area includes clear space with a minimum dimension of a circle with a six-
foot diameter.
Does not comply. Some of the
units with balconies can not
have a clear space with a
minimum dimension of a circle
with a 6 foot diameter.
☒(B) Minimum clear height dimension of 8’-6” feet. Complies
☒(C) Directly accessible from a residential unit.Complies
☐(C) Balconies are not located within the daylight plane.
(b)(1)(E) Private Open Space - Ground Floor Patios
☐
(i) RM-20 and RM-30 districts: Minimum 100 sf of area, the least dimension of which is
8 feet for at least 75% of the area.
☐
(ii) RM-40 districts: Minimum 80 sf of area, the least dimension of which is 6 feet for at
least 75% of the area
☐
(iii) Street facing private open space on the ground floor shall meet the finished floor
height for ground floor residential standards in section 18.24.040(b)(4)
(b)(2) Common Open Space
☒(A)&(B) Minimum 200 sf of area. Area shall include a space with a minimum dimension
of a circle with a 10-foot diameter.
AP2.03
AP2.06 Complies
City of Palo Alto - Objective Design Standards Checklist
Page 18
☒(C) A minimum of 60% of the area shall be open to the sky and free of permanent
weather protection or encroachments. Trellises and similar open-air features allowed
AP2.03
AP2.06
☒
(D) Notwithstanding subsection (1), courtyards enclosed on four sides shall have a
minimum dimension of 40 feet and have a minimum courtyard width to building
height ratio of 1:1.25
AP2.03
AP2.06
☒(E) Common open space provides seating. AP2.03
AP2.06
☒(F) Common open space has a minimum 20% of landscaping.AP2.03
AP2.06
☒(G) Planting in above grade courtyards has minimum soil depth of 12 inches for ground
cover, 20 inches for shrubs, and 36 inches for trees.
18.24.090 Materials
Check Standard Sheet #Applicant’s Justification
☒
(b)(1) Primary, secondary, and accent materials are allowed or prohibited as in the
Residential and Residential Mixed-use Material List, which may be updated from time
to time by the Director of Planning with a recommendation by the ARB. See webpage
for list - https://www.cityofpaloalto.org/News-Articles/Planning-and-Development-
Services/Multifamily-Mixed-Use-Objective-Standards
Materials Comply
18.24.100 Sustainability and Green Building Code
Check Standard Sheet #Applicant’s Justification
☒
(b) See Chapter 16.14: California Green Building Standards additional requirements for
green building and sustainable design. Notwithstanding Section 18.24.010(c), these
regulations may not be modified through alternative compliance.
Project complies with Calgreen
Tier 2.
From:James Lloyd
To:Planning Commission
Cc:Clerk, City; City Attorney; City Mgr; PlannerOnDuty
Subject:public comment re item 2 for tonight"s Planning Commission meeting
Date:Wednesday, February 11, 2026 12:52:29 PM
Attachments:Palo Alto - 3606 El Camino Real - HAA Letter.pdf
CalHDF v LCF - compressed.pdf
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Dear Palo Alto Planning Commission,
Please see attached our public comment regarding item 2 for tonight's Planning Commission
meeting, the proposed 321-unit housing development project at 3606 El Camino Real, which
includes 38 units affordable to low-income households.
Sincerely,
James M. Lloyd
Director of Planning and Investigations
California Housing Defense Fund
CalHDF is grant & donation funded
Donate today -
Feb 11, 2026
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Re: Proposed Housing Development Project at 3606 El Camino Real
By email: Planning.Commission@paloalto.gov
Cc: city.clerk@CityofPaloAlto.org; city.attorney@cityofpaloalto.org;
CityMgr@cityofpaloalto.org; Planner@CityofPaloAlto.org;
Dear Palo Alto Planning Commission,
The California Housing Defense Fund (“CalHDF”) submits this letter to remind the City of its
obligation to abide by the Housing Accountability Act (“HAA”) and AB 130 when evaluating
the proposed 321-unit housing development project at 3606 El Camino Real, which includes
38 units affordable to low-income households.
Under the HAA,1 a city may not disapprove a qualifying affordable housing project (i.e., a
housing development project that provides a certain percent of the total units to
lower-income households, as defined by Health and Safety Code Section 50079.5) on the
grounds it does not comply with the city’s zoning and general plan if the developer
submitted either a statutorily defined "preliminary application" or a "complete development
application" while the city's housing element was not in substantial compliance with state
law. (See Gov. Code, § 65589.5, subds. (d)(5), (h)(5), (o)(1).2) This statutory provision temporarily
suspends the power of non-compliant municipalities to enforce their zoning rules against
qualifying affordable housing projects. (See, e.g., California Housing Defense Fund v. City of La
Cañada Flintridge, Case Number: 23STCP02614 (attached), for a recent court decision
affirming the plain language of the statute in this regard.) The City’s Housing Element was
not in substantial compliance with state law when the preliminary application under SB 330
was submitted. The City must therefore allow the project to be developed as proposed.
2 These code section numbers correspond to the HAA as it existed when the preliminary application
for the project at issue was submitted (i.e. before AB 1893 went into effect).
1 AB 1893, effective January 1, 2025, has amended the “Builder’s Remedy” provisions of the HAA.
However, the AB 1893 allows for vested Builder’s Remedy applications to proceed under the previous
version of the law or the new version of the law.
2201 Broadway, PH1, Oakland, CA 94612
www.calhdf.org
CalHDF also notes that the City’s Housing Element has planned for 37 units on the project
site, including 12 lower-income housing units. Failure to approve this project would risk
de-certification of the City’s Housing Element by the California Department of Housing and
Community Development.
Furthermore, the project is eligible for a statutory exemption from CEQA review under AB
130 (Pub. Res. Code, § 21080.66). Caselaw from the California Court of Appeal affirms that
local governments err, and may be sued, when they improperly refuse to grant a project a
CEQA exemption or streamlined CEQA review to which it is entitled. (Hilltop Group, Inc. v.
County of San Diego (2024) 99 Cal.App.5th 890, 911.)
As you are well aware, California remains in the throes of a statewide crisis-level housing
shortage. New housing such as this is a public benefit: it will provide badly-needed
affordable housing; it will bring new customers to local businesses; it will increase the city’s
tax revenue; and it will reduce displacement of existing residents by reducing competition
for existing housing. It will also help cut down on transportation-related greenhouse gas
emissions by providing housing in denser, more urban areas, as opposed to farther-flung
regions in the state (and out of state). While no one project will solve the statewide housing
crisis, the proposed development is a step in the right direction. CalHDF urges the City to
approve it, consistent with its obligations under state law.
CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for
increased access to housing for Californians at all income levels, including low-income
households. You may learn more about CalHDF at www.calhdf.org.
Sincerely,
Dylan Casey
CalHDF Executive Director
James M. Lloyd
CalHDF Director of Planning and Investigations
2 of 2
From:
To:Planning Commission
Cc:Switzer, Steven; Armer, Jennifer
Subject:3606 ECR agenda item
Date:Wednesday, February 11, 2026 10:48:52 AM
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!
Dear Commissioners,
I support the staff recommendation to approve the Vesting Tentative Map.
This project is in the expanded ECR focus area approved by PTC and council.
It will bring more than 300 new housing units on an excellent site and will include roughly
40 units reserved for low income residents as required by law.
Given the financial (and legal) challenges facing 100% BMR projects, this project like the
approved 3150 ECR project are the most practical current way to increase our stock of BMR
housing.
The PTC and council have developed some momentum on new housing.
Please keep this going tonight while adding your comments to council.
Thanks
Stephen Levy
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From:slevy@ccsce.com
To:Planning Commission
Cc:Switzer, Steven; Armer, Jennifer
Subject:3606 ECR agenda item
Date:Wednesday, February 11, 2026 10:48:56 AM
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!
Dear Commissioners,
I support the staff recommendation to approve the Vesting Tentative Map.
This project is in the expanded ECR focus area approved by PTC and council.
It will bring more than 300 new housing units on an excellent site and will include roughly
40 units reserved for low income residents as required by law.
Given the financial (and legal) challenges facing 100% BMR projects, this project like the
approved 3150 ECR project are the most practical current way to increase our stock of BMR
housing.
The PTC and council have developed some momentum on new housing.
Please keep this going tonight while adding your comments to council.
Thanks
Stephen Levy
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From:slevy@ccsce.com
To:Architectural Review Board; Switzer, Steven
Subject:3606 ECR
Date:Tuesday, December 2, 2025 7:43:59 AM
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!
Dear Chair Chen and board members,
I look forward to supporting this project when it gets to the city council.
I also look forward to your comments, which usually make projects better.
From the perspective of meeting our city's housing goals this site and project have many
positives:
--it is on a site designated for substantial housing and approved by ARB and council in the
expanded ECR Focus Area.
--the site is close to the Cal Ave shopping area and train station as well as very close to the
Stanford Research Park and accessible to ECR bus lines.
--It is similar in many ways to the 3150 ECR project approved by ARB and council and will
bring a substantial number of new units on a single site
--the site is adjacent to two schools that are facing cutbacks from declining enrollment and
will help preserve these neighborhood schools at full service levels.
--the 37 BMR units, that are reserved for low income HH, will make a positive contribution
to meeting our low income housing goals in a very desirable area.
As always I am aware of the tension between making major changes to a proposal and
affecting the economic viability of the application.
Thank you for your hard and thoughtful work.
Stephen Levy
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From:Velasquez, Ingrid
To:Lait, Jonathan; Tran, Vickie; Switzer, Steven
Cc:Nose, Kiely; Gaines, Chantal; City Mgr
Subject:FW: 3606 El Camino Real Application #: 24PLN-00162
Date:Tuesday, February 17, 2026 9:21:08 AM
Attachments:image001.png
image002.png
image003.png
Hello all,
Forwarding the message below for awareness.
Thanks,
Ingrid
Ingrid Velásquez
Administrative Assistant
Office of the City Manager
(650) 329-2354| Ingrid.Velasquez@PaloAlto.gov
www.PaloAlto.gov
From: Ken Nishimura <nishimura.ken@gmail.com>
Sent: Thursday, February 12, 2026 3:24 PM
To: Council, City <city.council@PaloAlto.gov>; Switzer, Steven <Steven.Switzer@paloalto.gov>
Subject: 3606 El Camino Real Application #: 24PLN-00162
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Dear Palo Alto City Council - I read with some interest an article in the local newspaper regarding the proposed merger of parcels and construction of a large residential complex on 3606 El Camino Real between two streets, Matadero and Kendall. The Planning Commission correctly f
i
This message needs your attention
This is a personal email address.
This is their first mail to some recipients.
Mark Safe Report
CGBANNERINDICATOR
Dear Palo Alto City Council -
Powered by Mimecast
I read with some interest an article in the local newspaper regarding the proposed merger of
parcels and construction of a large residential complex on 3606 El Camino Real between two
streets, Matadero and Kendall.
The Planning Commission correctly found that there are serious concerns regarding traffic
circulation which would be realized should this development come to fruition. Specifically, the
ingress and egress of a large number of vehicles to/from Matadero so close to the intersection
with El Camino presents significant hazards to cyclists who use Matadero as a thoroughfare.
Given the limited number of crossings across the Caltrain tracks -- a topic of
significant concern in of itself -- cyclists who are in general trying to go from Downtown to the
southwest side of the city to access the industrial parks or Foothill Expressway have limited
options. I personally use the California Avenue underpass and ride along Park Avenue and
cross El Camino at Matadero to join the Bol Park path, reversing the route to go home. Note
that this is the first available "through" crossing of El Camino south of Page Mill with a traffic
signal.
The intersection of Matadero and El Camino is not engineered to handle the volume of traffic
anticipated by a large residential complex; light cycles are long and cars would back up into the
complex parking lot which then presents a hazard to cyclists as drivers would be motivated to
"make the light" rather than be aware of cyclists. This cycling route is used by bike commuters
as well as students going to nearby schools. Pedestrians also use this route as evidenced by a
school crossing guard at this intersection.
I urge the Council to require a significant modification to the plans prior to approving a parcel
merger, specifically one which mitigates ingress/egress onto streets which would create
hazards for cyclists and pedestrians.
Regards,
Ken Nishimura
From:Switzer, Steven
To:Star Teachout
Cc:Planning Commission; Architectural Review Board; John King; City Mgr
Subject:RE: 3606 ECR Driveway already exists
Date:Tuesday, December 9, 2025 4:47:00 PM
Attachments:image001.png
image002.png
Hi Star,
Thanks for your continued interest in the project located at 3606 El Camino Real that just went
before the Architectural Review Board at their December 4, 2025, Meeting.
The City’s Objective Standards (PAMC 18.16.090) provides parameters for parking design.
Where possible it is recommended that parking is accessed from side streets or alleys (PAMC
18.16.090(b)(6)(I)). The project proposes a design that would align with screening the parking
and having it accessed from a side street.
Because this is a “builder’s remedy project” under AB 1893, the City is limited to enforcing only
those objective standards that apply in a zone or land use designation that allows the
requested density. In the El Camino Real Focus Area, there is no requirement that driveways
be located on El Camino Real.
The applicant may also use incentives, concessions, or waivers under State Density Bonus
Law when demonstrating compliance with the enforceable standards. For example, even if the
City requested a driveway relocation, the applicant could lawfully seek a waiver/concession to
keep the current design.
Since the applicant is invoking AB 130, the project qualifies for a statutory environmental
exemption. AB 130 (effective June 30, 2025) is a significant reform to California Housing Law
and CEQA. In short, these reforms limit CEQA review but still require that a qualified
environmental professional identify any Recognized Environmental Conditions or
contamination concerns. If issues are found, the applicant must implement mitigation before
the project can move forward.
The City is still evaluating the project and your comments have been added to the project file.
For more information I have added a few helpful links below:
“Builder’s Remedy” and Housing Elements.
AB 130 Legislation
Governor Newsom signs into law groundbreaking reforms to build more housing, boost
affordability | Governor of California
As we continue to process the application, feel free to check the project’s webpage for
updates:
3606 El Camino Real – City of Palo Alto, CA
Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | Steven.Switzer@PaloAlto.gov
www.PaloAlto.gov
From: Star Teachout <teachout@sonic.net>
Sent: Tuesday, December 9, 2025 4:08 PM
To: Switzer, Steven <Steven.Switzer@paloalto.gov>
Cc: Planning Commission <Planning.Commission@PaloAlto.gov>; Architectural Review Board
<arb@PaloAlto.gov>; John King <johnwadeking@gmail.com>; Council, City
<city.council@PaloAlto.gov>
Subject: 3606 ECR Driveway already exists
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Steven,
I assume you already know this, but there is probably no need for an encroachment permit for
3606 ECR as there is already a well-placed driveway/curb cut at approximately the middle of
the el Camino Real frontage for this project. It would require an amendment to widen it, but it is
well placed--does not interfere with the bus stop closer to Matadero, and there is also a break
in the bike lane striping (and no white bollards), as if anticipating this project having a front
driveway. I would imagine this is a positive for the developers. This also addresses the ARB
comments about breaking up the continuous, visual mass from Matadero to Kendall of the
current design.
Since the ARB meeting was the first I attended, were you aware of the existing driveway, and
has it gotten discussed in any presentations/analyses so far? If so, what might be the
objections to using this placement (per my 8 December email below)?
Thanks for helping me understand the parameters of this project,
Star Teachout
++++++++++++++++++++++++++++++++
Record of other emails on this matter...
8 December email:
Hello Steven,
I apologize if I am late to evaluating the 3606 El Camino Real development project. In response
to your 4 Dec 2025 reply, it would be helpful if you would offer the statutes/codes/standards
which support your claims that a driveway on ECR would not be allowed due to city standards
and state regulations related to bike lanes. In the best possible world, we would be able to
develop properties for increased housing with the support of our community. Towards that
aim, providing information educates all of us with hopefully the least amount of community
strife, especially with the complexities of Builder’s Remedy. To be clear, I am not asking for any
of the following:
- The item 5 list is not presupposing they be conditions of approval, rather, asking what legal
mitigations the city can undertake after the project is approved [to prevent traffic hazards]
- CEQA compliance
- Reduced density
- Typical zoning compliance
- Anything that (I think) makes the project infeasible.
Driveway on El Camino Real
Did the City of Palo Alto refuse to allow a driveway onto ECR? If so, please provide a link to that
discussion or notes. Was a County of Santa Clara encroachment permit denied, and if so
appealed? If so, could you provide me with the dates related to that process? I have found
nothing in the codes listed below that prevent adding a driveway onto el Camino Real, even
through a bike lane. As previously mentioned, there will be driveways/egress from both 3150
and 3400 el camino real developments. Nor have I seen any requirement for even a traffic
study, unless the city were asking the applicant for that [no information I could find on such a
request]. Considering the potential for extreme disruption and associated safety hazards for
pedestrians, cyclists, and even drivers along Matadero and Kendall, this seems like an
essential route to pursue.
1. AB 3177 [supports land dedication for adding a service lane in the development plan on both
Matadero and Kendall, constricted/safe routes to schools roadways to prevent harm to
pedestrians, cyclists, and drivers]
AB 3177 does allow cities to impose such a land dedication requirement in the following
limited instances:
• When a housing development both (i) is not located in a transit priority area and (ii) has a
linear street frontage of 500 feet or more;
• Where the city makes a finding that the land dedication requirement is necessary to
preserve the health, safety, and welfare of the public, including pedestrians, cyclists,
and children; or
• To construct public improvements, including, but not limited to, sidewalk and sewer
improvements.
2. Project Development Procedures Manual (PDPM):
https://dot.ca.gov/programs/design/manual-project-development-procedures-manual-pdpm
3. Chap 17: Encroachments and Utilities: https://dot.ca.gov/-/media/dot-
media/programs/design/documents/pdpm-chapter17-a11y.pdf
4. Chapter 500 - Specific Encroachment Permits: https://dot.ca.gov/-/media/dot-
media/programs/traffic-operations/documents/encroachment-permits/epm-chapters-all-
ada-a11y.pdf
Thank you for clarifying anything I may have misinterpreted in these documents,
Star Teachout
+++++++++++++++++++++++
4 Dec email to ARB: sent separately after the ARB public meeting.
+++++++++++++++++++++++
4 Dec email exchange with Palo Alto planner Switzer:
On Dec 4, 2025, at 9:16 AM, Switzer, Steven <Steven.Switzer@paloalto.gov>
wrote:
Hi Star,
Having the two driveways into the garage enter onto El Camino Real would be in
conflict with our standards. Driveways are meant to be on cross streets rather
than entering onto a freeway like El Camino Real. Further, Caltrans recently added
bike lanes along that stretch of El Camino Real. Changing those bike lanes would
be unlikely to occur.
Since this is a Builder’s Remedy project, it is afforded a lot of protections from
compliance with zoning standards. The items you listed in #5 are unlikely to be
conditions of approval for the project because of this
Follow the link to read more information on “Builder’s Remedy” and Housing
Elements.
<image001.png>Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | Steven.Switzer@PaloAlto.gov
www.PaloAlto.gov
<image002.png>
From: Star Teachout <teachout@sonic.net>
Sent: Wednesday, December 3, 2025 6:10 PM
To: Switzer, Steven <Steven.Switzer@paloalto.gov>
Subject: Re: 3606 ECR questions
CAUTION: This email originated from outside of the organization. Becautious of opening attachments and clicking on links.
Thank you for the prompt reply. My highest priority questions are 3 and 5, the ones
you did not answer. I assume the city has some oversight on the arterial roads and
traffic those experience.
++++++++++++++++++
3 December email:
On Dec 3, 2025, at 5:18 PM, Switzer, Steven
<Steven.Switzer@paloalto.gov> wrote:
Hi Star,
My answers are below in bold.
Due to the nature of a builder’s remedy project, there are numerous
state law constraints on what the City can impose on a project.
<image001.png>Steven Switzer
Senior Historic Planner
Planning and Development Services
Department
650-329-2321 | Steven.Switzer@PaloAlto.gov
www.PaloAlto.gov
<image002.png>
From: Star Teachout <teachout@sonic.net>
Sent: Wednesday, December 3, 2025 1:58 PM
To: Switzer, Steven <Steven.Switzer@paloalto.gov>
Subject: 3606 ECR questions
Hello Steven,
I mistakenly arrived this morning to voice some concerns about the 3606
ECR development. Since I have a few more hours, if you have time could
you please share any answers to the following questions?
Incidentally, although losing the Fish Market has been a significant impact
on our south PA neighborhood (and probably McDonalds for many too),
looking over the 3150 ECR development I am struck at what a great plan it
is. The 3606 seemed to want to copy many parts of it, but it is poorly
executed and in my opinion the wrong building (scale) in the wrong place.
1. RM30/RM40 heights violated: Since 3606 el Camino Real qualifies as a
Builders’ Remedy project, does that mean the RM-30 and RM-40 portions
of the development are allowed to exceed the city’s 30 and 40 ft height
limits, despite there being residential properties across the street?
Seven stories along el Camino may be fine, but extending those 7 stories
into the neighborhood (T-configuration/footprint), eclipsing the sky view of
the nearby apartments and houses is extreme. Were renters notified of
this development?
The Palo Alto Municipal Code requires notice of this public
hearing be published in a local paper and mailed to owners and
occupants of property within 600 feet of the subject property at
least ten days in advance. Notice of a public hearing for this
project was published in the Daily Post on November 21, 2025,
which is 14 days in advance of the meeting. Postcard mailing
occurred on November 19, 2025, which is 16 days in advance of
the meeting.
The project site is also located within the El Camino Real Focus
Area that allows a maximum height of 85 feet. The RM-30 and RM-
40 lots are part of that focus area.
2. Minimal Underground Parking: The height of the development is
definitely out of scale for apartments surrounding this proposal. Unlike
Creekside (3400 ECR) and the Fish Market/McDonald’s site (3150 ECR)
which have mostly underground parking, can the city of PA require mostly
underground parking for this project too?
Because the project is a “builder’s remedy project,” as defined in
AB 1893, the City is further limited to only enforcing those
objective standards that exist in a zone district or land use
designation that allows the density requested. Further, the
project applicant is also able to utilize incentives, concessions,
and waivers under State Density Bonus Law when demonstrating
compliance with the enforceable standards. This allows the
applicant to deviate from certain standards. The City cannot
require underground parking.
3. No Entrance/Exits on ECR: Unlike the aforementioned projects, why are
there no exits from this development onto el Camino Real (as per 3400
and 3150 ECR)? It is unbelievable that this project would subject the
neighborhoods to this much traffic for those avoiding ECR traffic,
especially with the No Right Turn on Red rule at Matadero. Kendall (curvy
and narrow) and Matadero (no bike lanes, parking on sides allowed, major
route to schools) are not designed for this volume.
As you know, Barron Park is landlocked on 2 sides so all traffic short-
cutting through the neighborhood streets coming from Creekside and 3606
(as currently proposed) will travel down 3 streets—Whitsell, Kendall,
Barron--through this sidewalk-less neighborhood.
There are also issues with the Matadero driveway passing between 2
smaller apartment buildings, posing some dangers for those living there.
4. Parking: Why should a developer be allowed to not provide parking for
all its residents but be allowed to lease parking?!!
Plans indicate 321 residential units and the required parking
spaces in the El Camino Real Focus Area are 1 space per 1 unit.
The project is proposing 391 spaces and compliant with the
zoning code.
5. Protections: What with all the proposed developments happening
between Page Mill and Los Robles, does the city have some authority to
enact any of the following:
a. Retain the driveways on both Matadero and Kendall for service
vehicles (garbage, deliveries, EMS), but disconnect them from the
residential parking.
b. If (a) is not possible, impose a R turn driveway exit only from
3606 ECR on the Matadero side (ie, no L turn) and a L turn only (ie, no R
turn exit) onto Kendal to protect the neighborhoods from all the cut
through traffic? This would probably require a short bike lane/sidewalk on
Kendall between ECR and Whitsell to protect children enroute to school.
c. If (a) is not possible, could the city (with neighborhood approval)
make Whitsell a cul-de-sac at Matadero to prevent both 3400 and 3606
ECR development traffic from using it as a short cut, thus protecting
pedestrians and cyclists. This adds some traffic to Kendall and Josina, but
really only from the few houses on the first block of Whitsell.
d. Install speed bumps on Kendall, Whitsell, Barron, and Josina as
needed.
e. Enact No Right Turn between 8:30 and 9:30 am Mon-Fri on
Matadero and Kendall.
f. Remove the ECR cross-lane access at Kendall, which is already
dangerous, and make Barron a fully-signaled intersection (not just a
signaled cross-walk when pushed).
g. Barron Ave is extremely restricted between ECR and Whitsell—
narrow, tree-lined. Perhaps it too needs a no turns between 8:30 - 9:30
am?
H. Matadero is already impacted by traffic and the No R on Red law
at ECR. What with the many large proposed developments, could the city
remove this restriction at Matadero? [12/8/25: Negotiate with the
county/state]
i. All of these larger developments do not provide for all the
potential parking needed, even 3150 which is a pretty stellar development.
Where are all the approximate 300 drivers going to park when ECR no
longer allows it? Some people may not use cars, but from my experience
as a cyclist, even my able-bodied, clever neighbors still hop in their cars to
travel 1 mile! [12/8/25: Parking permit program]
The Housing Accountability Act Section 65589.5(d) states that a
city cannot deny such a project or impose conditions of approval
that would render it infeasible unless it makes specified findings.
In order to be eligible for AB 130 a project must comply with
Public Resources Code (“PRC”) Section 21080.66. This section
offers a statutory exemption for certain housing development
projects from CEQA requirements, aiming to speed up the
approval process. In addition, the project is considered a
“builder’s remedy project” as defined in the recently adopted
Assembly Bill (AB) 1893. Accordingly, the project may not be
denied on the basis of inconsistency with the Zoning Ordinance or
Comprehensive Plan land use designation. The project is further
afforded numerous protections as detailed in the staff report.
Thanks for any useful input to guide our city into healthy development
which considers both the needs of future and current residents.
Star Teachout
3550 Whitsell Avenue
From:Switzer, Steven
To:"Star Teachout"
Subject:RE: 3606 ECR questions
Date:Wednesday, December 3, 2025 5:18:00 PM
Attachments:image001.png
image002.png
Hi Star,
My answers are below in bold.
Due to the nature of a builder’s remedy project, there are numerous state law constraints on
what the City can impose on a project.
Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | Steven.Switzer@PaloAlto.gov
www.PaloAlto.gov
From: Star Teachout <teachout@sonic.net>
Sent: Wednesday, December 3, 2025 1:58 PM
To: Switzer, Steven <Steven.Switzer@paloalto.gov>
Subject: 3606 ECR questions
Hello Steven,
I mistakenly arrived this morning to voice some concerns about the 3606 ECR development.
Since I have a few more hours, if you have time could you please share any answers to the
following questions? Incidentally, although losing the Fish Market has been a significant
impact on our south PA neighborhood (and probably McDonalds for many too),
looking over the 3150 ECR development I am struck at what a great plan it is. The
3606 seemed to want to copy many parts of it, but it is poorly executed and in my
opinion the wrong building (scale) in the wrong place.
1. RM30/RM40 heights violated: Since 3606 el Camino Real qualifies as a Builders’ Remedy
project, does that mean the RM-30 and RM-40 portions of the development are allowed to
exceed the city’s 30 and 40 ft height limits, despite there being residential properties across
the street?
Seven stories along el Camino may be fine, but extending those 7 stories into the neighborhood
(T-configuration/footprint), eclipsing the sky view of the nearby apartments and houses is
extreme. Were renters notified of this development?
The Palo Alto Municipal Code requires notice of this public hearing be published in a
local paper and mailed to owners and occupants of property within 600 feet of the
subject property at least ten days in advance. Notice of a public hearing for this
project was published in the Daily Post on November 21, 2025, which is 14 days in
advance of the meeting. Postcard mailing occurred on November 19, 2025, which is
16 days in advance of the meeting.
The project site is also located within the El Camino Real Focus Area that allows a
maximum height of 85 feet. The RM-30 and RM-40 lots are part of that focus area.
2. Minimal Underground Parking: The height of the development is definitely out of scale for
apartments surrounding this proposal. Unlike Creekside (3400 ECR) and the Fish
Market/McDonald’s site (3150 ECR) which have mostly underground parking, can the city of
PA require mostly underground parking for this project too?
Because the project is a “builder’s remedy project,” as defined in AB 1893, the City
is further limited to only enforcing those objective standards that exist in a zone
district or land use designation that allows the density requested. Further, the
project applicant is also able to utilize incentives, concessions, and waivers under
State Density Bonus Law when demonstrating compliance with the enforceable
standards. This allows the applicant to deviate from certain standards. The City
cannot require underground parking.
3. No Entrance/Exits on ECR: Unlike the aforementioned projects, why are there no exits from
this development onto el Camino Real (as per 3400 and 3150 ECR)? It is unbelievable that this
project would subject the neighborhoods to this much traffic for those avoiding ECR traffic,
especially with the No Right Turn on Red rule at Matadero. Kendall (curvy and narrow) and
Matadero (no bike lanes, parking on sides allowed, major route to schools) are not designed for
this volume.
As you know, Barron Park is landlocked on 2 sides so all traffic short-cutting through the
neighborhood streets coming from Creekside and 3606 (as currently proposed) will travel
down 3 streets—Whitsell, Kendall, Barron--through this sidewalk-less neighborhood.
There are also issues with the Matadero driveway passing between 2 smaller apartment
buildings, posing some dangers for those living there.
4. Parking: Why should a developer be allowed to not provide parking for all its residents but be
allowed to lease parking?!!
Plans indicate 321 residential units and the required parking spaces in the El
Camino Real Focus Area are 1 space per 1 unit. The project is proposing 391 spaces
and compliant with the zoning code.
5. Protections: What with all the proposed developments happening between Page Mill and
Los Robles, does the city have some authority to enact any of the following:
a. Retain the driveways on both Matadero and Kendall for service vehicles (garbage,
deliveries, EMS), but disconnect them from the residential parking.
b. If (a) is not possible, impose a R turn driveway exit only from 3606 ECR on the
Matadero side (ie, no L turn) and a L turn only (ie, no R turn exit) onto Kendal to protect the
neighborhoods from all the cut through traffic? This would probably require a short bike
lane/sidewalk on Kendall between ECR and Whitsell to protect children enroute to school.
c. If (a) is not possible, could the city (with neighborhood approval) make Whitsell a
cul-de-sac at Matadero to prevent both 3400 and 3606 ECR development traffic from using it
as a short cut, thus protecting pedestrians and cyclists. This adds some traffic to Kendall and
Josina, but really only from the few houses on the first block of Whitsell.
d. Install speed bumps on Kendall, Whitsell, Barron, and Josina as needed.
e. Enact No Right Turn between 8:30 and 9:30 am Mon-Fri on Matadero and Kendall.
f. Remove the ECR cross-lane access at Kendall, which is already dangerous, and
make Barron a fully-signaled intersection (not just a signaled cross-walk when pushed).
g. Barron Ave is extremely restricted between ECR and Whitsell—narrow, tree-lined.
Perhaps it too needs a no turns between 8:30 - 9:30 am?
H. Matadero is already impacted by traffic and the No R on Red law at ECR. What with
the many large proposed developments, could the city remove this restriction at Matadero?
i. All of these larger developments do not provide for all the potential parking needed,
even 3150 which is a pretty stellar development. Where are all the approximate 300 drivers
going to park when ECR no longer allows it? Some people may not use cars, but from my
experience as a cyclist, even my able-bodied, clever neighbors still hop in their cars to travel 1
mile!
The Housing Accountability Act Section 65589.5(d) states that a city cannot deny
such a project or impose conditions of approval that would render it infeasible
unless it makes specified findings.
In order to be eligible for AB 130 a project must comply with Public Resources Code
(“PRC”) Section 21080.66. This section offers a statutory exemption for certain
housing development projects from CEQA requirements, aiming to speed up the
approval process. In addition, the project is considered a “builder’s remedy
project” as defined in the recently adopted Assembly Bill (AB) 1893. Accordingly,
the project may not be denied on the basis of inconsistency with the Zoning
Ordinance or Comprehensive Plan land use designation. The project is further
afforded numerous protections as detailed in the staff report.
Thanks for any useful input to guide our city into healthy development which considers both the
needs of future and current residents.
Star Teachout
3550 Whitsell Avenue
From:Fei Li
To:Switzer, Steven
Subject:Re: 3606 El Camino Project
Date:Thursday, November 20, 2025 3:22:31 PM
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Hi Steven,
Thank you for taking the time getting back to me, I really appreciate it. I will check the
website on regular basis to stay informed.
Hope you have a wonderful holiday season.
Fei
On Thu, Nov 20, 2025 at 11:38 AM Switzer, Steven <Steven.Switzer@paloalto.gov> wrote:
Hi Fei,
For project updates, feel free to contact me or visit the project’s webpage: 3606 El Camino
Real.
We are tentatively scheduled for the upcoming December 4th Architectural Review
Board (ARB) Meeting. You are welcome to attend that meeting at 8:30 am via zoom or in-
person to provide comments. Alternatively, you can provide written comments on the
project prior to the public hearing.
As for demolition, the project would need to be approved prior to obtaining any permits for
demolition. It is hard to give an exact timeline, but it is unlikely that it would occur within
the next year. Your property manager/landlord would also be a great resource to contact
about how to plan for a potential move.
Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | Steven.Switzer@PaloAlto.gov
www.PaloAlto.gov
From: Fei Li <fei.lee@gmail.com>
Sent: Thursday, November 13, 2025 12:46 PM
To: Switzer, Steven <Steven.Switzer@paloalto.gov>
Subject: 3606 El Camino Project
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments
and clicking on links.
Good afternoon Steven,
Hope this email finds you well. I am a resident of 528 Kendall Ave, Palo Alto, CA 94306
and I noticed a recent update on
3606 El Camino Project
https://www.paloalto.gov/Departments/Planning-Development-Services/Current-
Planning/Projects/3606-El-Camino-Real
Do you have a rough time line you you can share with me about the demolition so that I can
plan accordingly?
Thank you and I am looking forward to hearing from you.
Best regards,
Fei
From:Fei Li
To:Switzer, Steven
Subject:Re: 3606 El Camino Real Project started?
Date:Monday, June 9, 2025 11:44:41 AM
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i
Hi Steven,
Thanks for the information, have a great day!
Fei
On Mon, Jun 9, 2025 at 11:32 AM Switzer, Steven <Steven.Switzer@paloalto.gov> wrote:
Thanks for the image.
The project is still under review, so no work has been approved with regards to the planning
entitlement.
The truck pictured might be related to another item that is out of the project scope.
Steven Switzer
Historic Preservation Planner
Planning and Development Services Department
650-329-2321 | Steven.Switzer@PaloAlto.gov
www.PaloAlto.gov
This message needs your attention
This is a personal email address.
Mark Safe Report
From: Fei Li <fei.lee@gmail.com>
Sent: Saturday, June 7, 2025 1:31 PM
To: Switzer, Steven <Steven.Switzer@paloalto.gov>
Subject: 3606 El Camino Real Project started?
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Hi Steven,
I am a resident of 528 Kendall Ave, Palo Alto, CA 94306, which is part of 3606 El Camino
Real project. I reached to your team before regarding to the project and I noticed people
started working on the empty land in front of it this weekend.
Is the project started already? And do you have an estimation when will 528 Kendall Ave
building be demolished?
Thank you,
Fei
From:Art Liberman
To:Switzer, Steven
Cc:Helen Wang; Kellie Stafford; Kristan Green; John King; Dror Katzav; Mircea
Subject:Re: ARB 12/4/25 24LPN-00162
Date:Monday, November 24, 2025 6:00:56 PM
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i
Mr. Switzer - the plans for 3606 El Camino show the entry and exit from parking for all
the apartments going onto Matadero Avenue (Site Plan). Matadero Avenue is a
narrow street with space for one traffic lane in each direction. It is a collector street,
being one of only two streets that go into and out of Barron Park that have signalized
intersections on El Camino. Furthermore, Matadero is a designated Bicycle Boulevard
by the City of Palo Alto and is also a safe route for children who walk to and from
school (iit is on the Walk and Roll Map for Barron Park Elementary School). Because
there are Bicycle Lanes on El Camino, the City of Palo Alto has instituted No Right
Turn on Red at this and every signalized intersection with El Camino. Unless this
plan is changed, i think you and anyone with any knowledge of the neighborhood
would know that the backup and gridlock on Matadero would become horrendous
each and every morning! In fact, people living at this address may not be able to
leave their apartment. The Creekside Inn project, across Matadero Avenue from this
project initially had exit and entrance from parking on Matadero Avenue but they
changed their plans to have entrance and exit from El Camino. Something similar
needs to change for this project as well.
Art Liberman
member of PABAC
On Monday, November 24, 2025 at 01:58:36 PM PST, Switzer, Steven <steven.switzer@paloalto.gov>
wrote:
Hi Micrea,
The plans are quite large to send via email. However, the plans are available online at the
following webpage:
https://www.paloalto.gov/Departments/Planning-Development-Services/Current-
This message needs your attention
This is a personal email address.
This is their first mail to some recipients.
Mark Safe Report
Planning/Projects/3606-El-Camino-Real
A staff report will be published later this week detailing the project’s consistencies and
inconsistencies with applicable standards.
Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | Steven.Switzer@PaloAlto.gov
www.PaloAlto.gov
From: Mircea <mircea27v@gmail.com>
Sent: Monday, November 24, 2025 12:13 PM
To: Switzer, Steven <Steven.Switzer@paloalto.gov>
Cc: Helen Wang <theyuwang@gmail.com>; Kellie Stafford <kkstafford72@gmail.com>;
Liberman, Art <art_liberman@yahoo.com>; Kristan Green <kristangreen@mac.com>; John
King <johnwadeking@gmail.com>; Dror Katzav <dror.katzav@gmail.com>
Subject: ARB 12/4/25 24LPN-00162
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and clicking on links.
Steven,
Could you please send me an email with the submitted plans and any reports that quantify why the development is
entitled as a 7-story building with 13% BMR? It appears this may involve an infill exception under AB 130, and I
would like to review the basis for that determination.
I’m also interested in understanding how the transition to residential has been addressed on CN, RM-30, RM-40
and what is the zoning used for the entire project?
Thanks,
Mircea
650-996-1114
From:Penny Brennan
To:Switzer, Steven
Subject:Re: Public Comment on Major Arch Review App for 3606 El Camino [24PLN-00162] (12-4-25 meeting)
Date:Thursday, December 4, 2025 5:32:29 PM
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i
Hi Steven,
Thank you for your response to my comments. Unfortunately, because I was alloted only 2
minutes to speak, I was unable to read out the points regarding hazards posed by this project to
children bicycling to Barron Park, Fletcher, and Gunn schools, and potential earthquake and
fire emergency issues related to this very large, high density building. I hope that the ARB will
read my email that included these points and that the information my email contained will
reach City Council along with other material pertaining to the proposed project. If you think it
will not reach City Council, do you advise me sending a new email to them so that my
opinions will be read by them?
I have one additional comment after attending the ARC meeting this morning. During the meeting I was somewhat
shocked to learn that the building designers have placed the main entry/exit for cars, people, Uber/Lyft pick-ups, and
deliveries at the Matadero side of the building, close to the intersection of Matadero and El Camino. The designers
and Board seemed unconcerned about, or perhaps unaware of, the narrowness of Matadero there, Matadero as an
already conjested traffic corrider at certain times of day, and as a major bicycling route for Ventura kids going
to/coming from school, and the fact that that entry way will face another housing project of major size, at the site of
what is now the Creekside Hotel. Is the plan for the Creekside Hotel property to also have its main entry on Matadero
near the intersection of Matadero and El Camino? The current placement of the main entrance to 3606 El Camino on
Matadero, near the intersection of Matadero and El Camino, is quite problematic.
Thank you for considering my comments and your help steering them to the proper recipients.
Best regards,
Penny
On Thu, Dec 4, 2025 at 9:58 AM Switzer, Steven <Steven.Switzer@paloalto.gov> wrote:
Hi Penny,
This message needs your attention
This is a personal email address.
Mark Safe Report
Thank you for the public comment on this item. I will add it to the project file.
While it past the time to be added with the posted agenda packet, I would invite you to speak
at the meeting today and voice your comments.
We will send these public comments to the ARB with the next meeting packet.
Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | Steven.Switzer@PaloAlto.gov
www.PaloAlto.gov
From: Penny Brennan <plynnbrennan@gmail.com>
Sent: Thursday, December 4, 2025 12:15 AM
To: Architectural Review Board <arb@PaloAlto.gov>
Cc: Switzer, Steven <Steven.Switzer@paloalto.gov>
Subject: Public Comment on Major Arch Review App for 3606 El Camino [24PLN-00162] (12-4-25
meeting)
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Dear Architectural Review Board:
I am writing with reference to the Major Architectural Review Application for 3606 El
Camino Real [24PLN-00162], to be discussed at the 12-4-25 meeting of the Architectural
Review Board.
My name is Penny Brennan. I live about half-way down East Matadero Ave, across El
Camino from the proposed building site, in the Ventura neighborhood.
It appears from the addresses of the to-be-demolished buildings that the footprint for the
proposed project will span El Camino between Matadero Ave and Kendall Avenue,
lengthwise; depth-wise it will span almost 2 blocks from El Camino toward Whitsell.
I oppose the proposed project for several reasons:
1. A high density (321 units), 7-story building at this location would be at dramatic odds
with the appearance and character of the Barron Park and Ventura neighborhoods it would
be placed in and adjacent to. If it is designed similarly to most of the recently built
developments along El Camino, it will have a modern, concrete-and-glass urban design
completely at variance with the almost rural, single-family residential character of the
surrounding Barron Park neighborhood and with the post-WW II Palo Alto "working class"
character of the Ventura neighborhood across the street from it.
2. A 7-story building at this location is going to tower and loom over that part of the Barron
Park and Ventura neighborhoods. For example, from my kitchen window, which faces El
Camino, I look out now at my neighbors' trees and the sky above them. If the proposed
building is constructed, this view will be replaced by a view of six stories of concrete siding
and glass windows.
3. I estimate that a building with 321 units will represent a population of at least 600-1300
individuals. Likely residents of each unit will own 1-2 cars, translating to 300-600 vehicles
that will require parking and egress to and from the building complex.
a. What is the parking plan for all of these cars? There are no, or almost no, available
parking places along the streets bordering the proposed project (El Camino, Matadero, and
Kendall), and parking has become severely limited on the streets across the street from the
proposed site (Margarita, E. Matadero, and Wilton) due to recent implementation of
dedicated bike lanes along El Camino and the popularity of restaurants (such as the Hong
Kong Restaurant) and other businesses across the street from the proposed site.
b. Egress of 300-600 cars to and from the proposed building site on to El Camino via
Matadero and Kendall will be problematic. These are both very narrow streets, already well-
populated with cars seeking access to and from the Barron Park neighborhood.
c. I am concerned about the safety of bicyclists who would need to share the Matadero,
Kendall, and Whitsell roads with the 300-600 new vehicles the proposed building would
bring. The Matadero-El Camino intersection, and the narrow Matadero street beyond it, are
already hazardous for the many children who ride their bikes from the Ventura
neighborhood to their Barron Park Elementary, Fletcher Middle, and Gunn High schools.
The danger will only increase if these and other bicyclists must compete for safe space with
the 300-600 additional cars the proposed 321 unit, 7-story development will bring.
4. I am also concerned about earthquake and fire safety related to development of such a tall,
high density building in the Barron Park and Ventura neighborhoods. To what extent might
neighboring and nearby residents in 1-2 story homes be put at risk of physical harm by
catastrophic earthquake and fire events in the proposed very tall, high-density building?
How might evacuation, rescue, and other emergency efforts be hampered by the size,
density, and poor egress of the proposed building? In the event of earthquake and fire
emergencies, does Palo Alto have sufficient emergency services resources to respond
adequately to emergency needs of the 600-1300 residents in this building in addition to the
needs of existing residents in the Barron Park and Ventura neighborhoods?
Thank you for considering my concerns as you make decisions about the suitability of the
proposed project for the Barron Park and Ventura neighborhoods of Palo Alto.
Sincerely,
Penny Brennan, PhD
Ventura Neighborhood
From:Penny Brennan
To:Planning Commission
Cc:Armer, Jennifer; Switzer, Steven
Subject:"NO" on 3606 El Camino proposed project
Date:Thursday, February 5, 2026 9:01:28 AM
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Dear Members of the Palo Alto Planning and Transportation Commission,
I am writing to ask that you send a "NO" recommendation to the Palo Alto City Council
regarding approval of the proposed 3606 El Camino building project.
The plan to build a 7-story, 321- unit building at 3606 El Camino Real was passed on to City
Council for approval by the Architectural Review Board (ARC) on December 4, 2025. In the
December 4 meeting, ARC did not consider serious safety hazards that the project poses to
Palo Alto residents who live nearby in the Barron Park and Ventura neighborhoods. I am
hoping you will do so.
As you know, the site of the proposed 3606 El Camino project spans the length of El Camino
between Kendall Avenue and Matadero Avenue. Both of these are narrow, 2-lane roads. The
proposed project sits diagonally on the busy, 4-lane intersection of El Camino Real and
Matadero-Margarita Avenues.
The new dedicated bike lanes along El Camino Real prevent placement of the building's main
entry/exit on El Camino Real. The building's designers have sited its main entry/exit on
Matadero Avenue, close to the intersection of El Camino Real and Matadero-Margarita
Avenues. The renderings shown by the designers during the December 4 ARC meeting
suggested that Matadero Avenue is a boulevard of the same size and dimensions as El Camino
Real. It is not. It is a narrow, 2-lane road, with no sidewalks and little parking; cars frequently
park blocking the bike lanes, along its length stretching to Bol Park.
At the December 4 ARC meeting there was no discussion among ARC members of safety
hazards posed by the placement of the main entry/exit of a 7-story, 321 unit building on
Matadero Avenue, proximal to the busy intersection of El Camino Real and Matadero-
Margarita Avenues. Every one of the building residents' > 300 vehicles, and those of their
visitors, as well as delivery trucks, service providers, Ubers/Lyfts, building maintenance, and
other vehicles will have to enter and exit the building through this Matadero main entry/exit.
ARC did not discuss how pedestrians can safely negotiate through/past this busy, vehicle-
heavy entry/exit.
Note that the new Creekside Inn housing development will be sited at the other corner of El
Camino Real and Matadero Avenue, across the street from 3606 El Camino's Matadero main
main entry/exit. The Creekside Inn development cannot site its main entry on El Camino Real
due to the new El Camino Real dedicated bike lanes. Is it the plan to also site the Creekside
Inn project's main entry/exit on Matadero Avenue, so that it will be directly across the street
from 3606 El Camino's main entry/exit?
The intersection of El Camino Real and Matadero-Margarita is going to become an extremely
hazardous traffic nightmare. There will be a back up of the many vehicles that need to access
the 3606 El Camino building's Matadero Avenue building entrance via the southbound lane of
El Camino Real, and many of these vehicles already disregard the rule that prohibits
occupation of/right turns on red over the dedicated bike there. This will pose ongoing danger
to bicyclists traveling southbound along El Camino Real. It is not clear how these vehicles, or
northbound vehicles making lefts off El Camino on to Matadero, can make their next left, into
the Matadero main entry/exit, without blocking the considerable traffic headed up Matadero
toward El Camino Real to exit the Barron Park neighborhood. Note that, if you miss your left
turn into the Matadero main exit/entry, there are no good U-turn opportunities later down
Matadero to correct your course. The Barron Park region of Palo Alto is semi-rural in road
structure, featuring narrow, often winding roads without sidewalks. Drivers will seek U-turn
opportunities by driving further down the narrow Matadero road toward Bol Park, or into the
narrow Barron Park neighborhood streets, to use residents' driveways to make their U-turns
back toward the 3606 El Camino building. Speeding cars on Barron Park streets are already
hazardous for pedestrians and bicyclists. Incursion of more vehicles whose drivers seek U-
turns back to 3606 El Camino will only increase this danger.
My biggest concern is for the safety of bicyclists, most of them children, who must cross the
El Camino Real - Matadero/Margarita intersection to travel down narrow Matadero, then other
narrow, winding Barron Park streets, to reach their destinations of Barron Park Elementary,
Fletcher Middle, and Gunn High schools. This intersection is already harrowing, and biking
through Barron Park roads is already dangerous for the children who commute to Barron Park
Elementary, Fletcher Middle, and Gunn High schools, as well as adults bicycling to Stanford
and adjacent Industrial Park businesses. The increased volume of vehicles on these roads, and
traffic problems caused by the siting of the 3606 El Camino building main entry/exit on
Matadero Avenue, are going to vastly increase this danger.
I have one other concern regarding safety of the proposed 7-story, 321 unit building at 3606 El
Camino. I am very concerned about earthquake and fire safety related to construction of such a
tall, high density building at this location. To what extent might neighboring and nearby
residents in 1-2 story homes be put at risk of physical harm by catastrophic earthquake and fire
events in the proposed 7-story, 321-unit building? How might fire fighting, evacuation, rescue,
and other emergency service efforts be hampered by the height, density, poor egress, and
narrow streets surrounding the proposed building? In the event of earthquake and fire
emergencies, does Palo Alto have sufficient emergency services resources to respond
adequately to emergency needs of the 600-1300 residents in this building, plus the needs of the
several hundred residents of the adjacent Creekside Inn building(s), in addition to the needs of
the existing residents, living in 1-2 story homes, in the Barron Park and Ventura
neighborhoods? I am concerned that the very tall, high density 3606 El Camino project
endangers the lives and safety of its neighbors by placing excessive burden on existing
emergency service resources allotted to this region of the city of Palo Alto.
I urge you to recommend "NO" to City Council regarding the proposed 3606 El Camino
project, on grounds of the serious safety hazards it poses Palo Alto residents in the Barron
Park and Ventura neighborhoods.
Sincerely,
Penny Brennan, PhD
Ventura Neighborhood
April 13th 2026
3606 El Camino Real Proposed Multifamily Project
Developer Letter
Dear Honorable Councilmembers,
We are pleased to present 3606 El Camino Real, a 321-unit multifamily residential development
that directly responds to Palo Alto's critical housing needs and the City's long-term vision for El
Camino Real. This project was filed in February 2024 under California's Builder's Remedy
provision — a state law that allows housing projects to proceed outside of local zoning
restrictions in jurisdictions whose Housing Element had not yet received HCD certification. At
the time of filing, Palo Alto's Housing Element had not been certified, which occurred in August
2024. The project also invokes State Density Bonus Law and Assembly Bill 130, which provides a
CEQA exemption for qualifying infill housing projects.
While this is not a conventional entitlement pathway, we have taken care to design a project
that is thoughtful, appropriately scaled, and reflective of the City's vision for El Camino Real. The
project delivers 321 units of new housing — including 37 units affordable to low-income
households at or below 80% AMI, consistent with AB 1893's affordability requirements. We
recognize that the project's affordability component has evolved since the original filing, and we
are committed to delivering these 37 BMR units as a meaningful contribution to the City's
housing goals.
Beyond housing, the project offers tangible community benefits: it activates an underutilized
commercial stretch of El Camino Real with an architecturally engaging building; it improves
streetscape conditions at the entrance to the Barron Park neighborhood , including adding
sidewalks where none currently exist; and it is broadly consistent with the El Camino Real Focus
Area Plan and its Objective Design Standards.
To date, the project has gone through two formal public review processes. At the Architectural
Review Board, we received design feedback that we incorporated into the current plans —
including a fin design motif at the Kendall corner, an accentuated massing break along El
Camino Real, enhanced landscaping on the south side to transition the building into the
neighborhood, and improved connections to the tertiary courtyard. Those changes
strengthened the design and are reflected in the current submittal.
At the Planning and Transportation Commission, questions were raised regarding the project's
garage access locations. The vehicle access follows Palo Alto's Objective Design Standards (ODS
18.24.030(b)) which states that “Vehicle access shall be located on alleys or side streets when
they abut the property.” This project benefits from distribution through two separate points of
vehicular entry — one on Matadero Avenue and one on Kendall Avenue. This approach reflects
standard traffic engineering practice: locating driveway access on side streets rather than
arterials reduces conflict points on high-volume roadways, and distributing access across two
locations spreads traffic more evenly across the surrounding street ne twork. The Palo Alto
objective design standard is particularly sensible for this site, because vehicle access on El
Camino Real would introduce substantial conflicts. El Camino Real has also been the subject of
recent public investment in separated bicycle infrastructure; an additional driveway cut along
that frontage would introduce a new vehicle-bicycle conflict point along those facilities. Further,
an independent review conducted by Hexagon Transportation Consultants evaluated the entry
locations and confirmed that the Matadero and Kendall entries are appropriately sited relative
to traffic distribution and street safety. We have further reinforced both entries with internal
stop signs and visual and audio warnings to alert pedestrians and cyclists when vehicles are
exiting. Combined with new sidewalk improvements along the project frontage on Matadero
and Kendall, these elements represent a meaningful net safety enhancement for the
surrounding neighborhood.
We are grateful to City Council, City staff, the ARB, and the PTC for the time and rigor they have
brought to reviewing this project. We look forward to your support for bringing 321 new homes
to Palo Alto.
Sincerely,
Alex Giovannotto
Vittoria Management, Inc.
3606 El Camino Real
Design Updates
Building Massing and Façade Articulation
ARB members expressed concern
that the building appears too long
and visually massive and
encouraged additional façade and
roofline breaks to reduce perceived
bulk.
1
1
2
Increased contrast at the
recessed massing break to more
clearly articulate the change in
plane and strengthen the
building’s visual breakdown.
2 Added roofline breaks to
reduced the perceived bulk of
the building.
ARB Comment
Design Response
Transition to Neighborhood
ARB members expressed concern about the
transition to adjacent lower-scale residential
areas and recommended strategies to reduce
impacts on neighboring properties.
1
1 Updated the podium level to include
landscaping along the south side to
soften the visual experience of 3606.
The building perimeter is lined with
trees to further soften the project’s
edge and enhance the transition to
neighboring properties.
ARB Comment
Design Response
2
2
Street- Facing Experience along Kendall
While parking is well screened from El
Camino Real, ARB members noted that the
Kendall-facing façade lacks sufficient
articulation and encouraged additional
façade breaks and design features to
enhance the pedestrian experience and
better screen the garage.
The Kendall/ECR corner was
enhanced to create a more prominent
corner presence and incorporate the
fin motif used at the Matadero corner,
fostering a more welcoming
pedestrian experience, adding design
interest, and maintaining the
effectiveness of the garage screening.
ARB Comment
Design Response
1
1
Existing Condition
Open Space and Amenity Design
ARB members noted that some third-floor
amenities appear underutilized or inaccessible
and recommended better connectivity, expanded
roof decks, and improved usability of shared open
spaces.
1
1 Shifted the floor plans to allow access
from the corridor to the small courtyard
on the south leg of the building.
Ensured that residential patios on the
podium provide as much usable
outdoor space as possible.
ARB Comment
Design Response
2
2
560 Mission Street, Suite 1900 | San Francisco, CA 94105 | T 415.743.6900 | F 415.743.6910
-743-6990
-743-6979
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April 25, 2025
- 5th Floor
Re: Invocation of “Builder’s Remedy 2.0” Under AB 1893, and CEQA Compliance
for the Housing Development Project at 3606 El Camino Real (24PLN-00162)
Dear All:
This firm represents Vittoria Management, Inc. (the “Applicant”) in connection with its application
for a housing development project consisting of 335 multifamily units (the “Project”) at 3606 El
Camino Real (the “Project Site”) in Palo Alto (the “City”). The City determined the Project’s
application complete for Permit Streamlining Act purposes on December 23, 2024. As explained
in more detail in our previous communication, the Project is protected by the Housing
Accountability Act (the “HAA”) inclusive of the Builder’s Remedy provision. The Applicant has
also secured vested rights to develop the Project pursuant to the Housing Crisis Act of 2019 (“SB
330”), and the Project Site has been included in the City’s housing site inventory for its 6th cycle
Housing Element.1 The purposes of this letter are to:
1. Document the Project’s eligibility for and affirmatively invoke the protections of Assembly
Bill (“AB”) 1893, also known as “Builder’s Remedy 2.0”; and
2. Document the Project’s eligibility for the protections of AB 1633 and the “Infill
Exemption” from the California Environmental Quality Act (“CEQA”), pursuant to CEQA
Guidelines Section 15332.
AB 1893’s Protections and Its Applicability
AB 1893 went into effect on January 1, 2025 and provides significant new protections for Builder’s
Remedy projects. Importantly, its new protections extend to proposals, including the Project, that
1 See the City’s 2023-2031 Housing Element, Appendix D: Site Inventory, available at:
https://paloaltohousingelement.com/wp-content/uploads/2024/08/Appendix-D_Site-Inventory.pdf.
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predate AB 1893’s effective date.2 AB 1893 allows Builder’s Remedy projects to include 13% low
income units,3 and for in-process projects switching to Builder’s Remedy 2.0 to make
modifications to their proposal even if they exceed a 20% change in units or square footage.4
The Applicant is hereby electing to convert to Builder’s Remedy 2.0 and include 13% low income
units (37 total units when calculated as a portion of the base maximum density per AB 1893) in
the now-revised Project. The Applicant reserves all rights it has including under the HAA as
amended by AB 1893, or any other state or local laws, to return to its original proposal for the
Project if warranted at a later time.
In addition to the above-described provisions, AB 1893 includes the following notable protections,
of which we wish to remind the City:
• Local agencies may not require a Builder’s Remedy 2.0 Project to apply for or receive
approval of a general plan amendment, specific plan amendment, rezoning, or other
legislative approval.5 Local agencies also may not require a Builder’s Remedy 2.0 Project
to apply for or receive any approval or permit not generally required of a non-Builder’s
Remedy project of the same type and density.6
• Local agencies may not adopt or impose any requirements (including fees), or undertaking
any course of conduct, with respect to Builder’s Remedy 2.0 Projects that do not apply to
other projects.7
• Builder’s Remedy 2.0 Projects are deemed consistent with all applicable local standards
and plans, and may not be treated as nonconforming uses.8
• Prior to AB 1893, the HAA provided only that jurisdictions could not “disapprove”
Builder’s Remedy projects, or condition such projects in a manner that rendered the
affordable portion of the project infeasible. AB 1893 has significantly expanded the scope
2 See Gov. Code § 65589.5(f)(7)(A) (as amended by AB 1893) (“For a housing development project application that
is deemed complete before January 1, 2025, the development proponent for the project may choose to be subject to
the provisions of this section that were in place on the date the preliminary application was submitted, or, if the project
meets the definition of a builder’s remedy project, it may choose to be subject to any or all of the provisions of this
section applicable as of January 1, 2025.”). See also Gov. Code § 65589.5(h)(5) (“Notwithstanding any other law,
until January 1, 2030, ‘deemed complete’ means that the applicant has submitted a preliminary application pursuant
to Section 65941.1 or, if the applicant has not submitted a preliminary application, has submitted a complete
application pursuant to Section 65943.”) (emphasis added).
3 Gov. Code §§ 65589.5(d); (h)(3)(C)(i)(III) (as amended by AB 1893).
4 Gov. Code § 65589.5(f)(7)(B) (as amended by AB 1893).
5 Gov. Code § 65589.5(f)(6)(D)(i) (as amended by AB 1893).
6 Gov. Code § 65589.5(f)(6)(D)(ii) (as amended by AB 1893).
7 Gov. Code § 65589.5(f)(6)(E) (as amended by AB 1893).
8 Gov. Code § 65589.5(f)(6)(D)(iii) (as amended by AB 1893).
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of prohibited actions. In addition to prohibiting a local agency from voting to disapprove a
Builder’s Remedy 2.0 Project, AB 1893 also notably prohibits local agencies from:
o Taking a “final administrative action” (other than a vote) that functions as a project
disapproval;9
o Subjecting a Builder’s Remedy 2.0 to more than five hearings;10
o Wrongfully determining that a Builder’s Remedy 2.0 Project preliminary
application has expired or failed to establish vested rights in contravention of the
Permit Streamlining Act;11
o Maintaining a “course of conduct undertaken for an improper purpose” that
functions as an “effective disapproval” of a Builder’s Remedy 2.0 Project.12
• AB 1893 also expands the HAA’s prohibition on unlawful conditioning. The local agency
is now prohibited from imposing any condition that would render the Builder’s Remedy
2.0 Project as a whole infeasible (rather than just the affordable component of the
project).13 The local agency is also now specifically prohibited from imposing a
combination of conditions that would render the Builder’s Remedy 2.0 Project infeasible.14
The Project qualifies for AB 1893, as documented in the following chart:
Summary of AB 1893 Criteria Project Consistency
Affordability (Gov. Code §
65589.5(h)(11)(A)).
The project is a housing development project
that provides housing for very low, low-, or
moderate-income households.
Gov. Code § 65589.5(h)(3): 55 years for
rental units, 45 years for ownership units.
“Housing for mixed-income households” =
Does the project satisfy one of the applicable
affordability percentage requirements?
• Yes, the Project includes 13% low
income units, calculated as a portion
of the base maximum.
Will the affordability of these units be ensured
for the required period?
9 Gov. Code § 65589.5(h)(6)(A) (as amended by AB 1893).
10 Gov. Code § 65589.5(h)(6)(E) (as amended by AB 1893).
11 Gov. Code § 65589.5(h)(6)(H) (as amended by AB 1893).
12 Gov. Code § 65589.5(h)(6)(D) (as amended by AB 1893).
13 Gov. Code § 65589.5(d) (as amended by AB 1893).
14 Gov. Code § 65589.5(f)(6)(B) (as amended by AB 1893).
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Summary of AB 1893 Criteria Project Consistency
•
or
• At least 10 % “very low income”; or
• At least 13% “low income” ; or
• Project contains 10 or fewer units, on a
site smaller than 1 acre, proposed at
•
affordability of the rental units for 55
years.
Housing element compliance (Gov. Code §
65589.5(h)(11)(B)).
When application was “deemed complete”
(this includes submission of SB 330
preliminary application or formal
application)15 the jurisdiction did not have a
housing element that was in substantial
compliance16 with this article.
At the time of preliminary application
submittal (or, if no preliminary application
was submitted, the time of submission of a
complete formal application), was the
jurisdiction’s housing element certified as
substantially compliant by HCD or a court of
competent jurisdiction?
• No – project qualifies for this
requirement.
Maximum density (Gov. Code §
65589.5(h)(11)(C)).
Must comply with the greatest of the
following densities (plus can add any density
bonus per State Density Bonus Law):
(i) The density does not exceed the greatest
of the following densities:
(I) Fifty percent greater than the minimum
density deemed appropriate to
accommodate housing for that jurisdiction
as specified in subparagraph (B) of
paragraph (3) of subdivision (c) of Section
Does the project comply with the applicable
maximum density?
• Yes – Explanation below
Using the options at left, we have identified
the highest density for each APN of the
Project Site, and calculated a weighted
average by percentage of the site that each
APN represents to determine the base
maximum density per AB 1893, as follows:
APN 137-08-016 = 30 Mullen + 50% = 45
du/acre + 35 for “high resource” tract = 80
15 Gov. Code § 65589.5(h)(5).
16 See Gov. Code § 65589.55(a) (“For purposes of a local agency’s approval, conditional approval, or disapproval of
a housing development project pursuant to subdivision (d) of Section 65589.5, a housing element or amendment
shall be considered in substantial compliance with this article only if the element or amendment was in substantial
compliance, as determined by the department or a court of competent jurisdiction, when a preliminary application,
including all of the information required by subdivision (a) of Section 65941.1, was submitted or, if a preliminary
application was not submitted, when a complete application pursuant to Section 65943 was submitted.”).
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Summary of AB 1893 Criteria Project Consistency
density”).
(II) Three times the density allowed by the
general plan, zoning ordinance, or state
law, whichever is greater.
(III) The density that is consistent with the
density specified in the housing element.
Add 35 du/acre to the maximum
summarized above, if any portion of the site
is located within any of the following:
(I) One-half mile of a major transit stop.18
(II) A very low vehicle travel area.
(III) A high or highest resource census
tract, as identified by the latest edition of
the “CTCAC/HCD Opportunity Map.”19
•
x 80 = 3.651 du/acre
APN 137-08-070 = 40 per zoning x 3 = 120
du/acre + 35 for “high resource” tract = 155
du/acre
• 5,103 square feet/113,907 square feet
x 155 = 6.944 du/acre
APN 137-08-077 = 40 per comp plan x 3 =
120 du/acre + 35 for “high resource” tract =
155 du/acre
• 38,058 square feet/113,907
x 155 = 51.788 du/acre
APN 137-08-079 = 30 Mullen + 50% = 45
du/acre + 35 for “high resource” tract = 80
du/acre
• 10,194 square feet/113,907 square feet
x 80 = 7.160 du/acre
APN 137-08-080 = 30 Mullen + 50% = 45
du/acre + 35 for “high resource” tract = 80
du/acre
• 28,350 square feet/113,907 square feet
x 80 = 19.911 du/acre
17 “The following densities shall be deemed appropriate to accommodate housing for lower income households: (i)
For an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan
area: sites allowing at least 15 units per acre. (ii) For an unincorporated area in a nonmetropolitan county not
included in clause (i): sites allowing at least 10 units per acre. (iii) For a suburban jurisdiction: sites allowing at least
20 units per acre. (iv) For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre.” Gov.
Code § 65583.2(c)(3)(B).
18 “‘Major transit stop’ means a site containing any of the following: (a) An existing rail or bus rapid transit station.
(b) A ferry terminal served by either a bus or rail transit service. (c) The intersection of two or more major bus
routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute
periods.” Pub. Res. Code § 21064.3.
19 See HCD, 2024 CTCAC Opportunity Map (https://belonging.berkeley.edu/final-2024-ctcac-hcd-opportunity-
map).
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Summary of AB 1893 Criteria Project Consistency
du/acre + 35 for “high resource” tract = 80
du/acre
• 16,275 square feet/113,907 square feet
x 80 = 11.430 du/acre
APN 137-08-088 = 30 Mullen + 50% = 45
du/acre + 35 for “high resource” tract = 80
du/acre
• 10,838 square feet/113,907 square feet
x 80 = 7.612 du/acre
3.651 + 6.944 + 51.788 + 7.160 + 19.911 +
11.430 + 7.612 = 108.496 du/acre base
maximum for the Project under AB 1893,
prior to using any State Density Bonus Law
bonus. This yields a 284 unit “base”
maximum.
The affordability requirement for AB 1893 is
a portion of the “base” maximum, making the
13% low income requirement equal to 37
units.
The Project achieves the currently proposed
335 units, because 13% low income units
achieves an up to 24.5% density bonus, and
284 (the base) + 70 (the maximum bonus) =
354 which is greater than the currently
Minimum density (Gov. Code §
65589.5(h)(11)(D)).
(i) On sites that have a minimum density
requirement and are located within 1/2 mile of
a commuter rail station or a heavy rail station,
cannot go below the minimum.
(ii) On all other sites with a minimum density
Does the site have a minimum density
requirement under the local zoning
ordinance? If so, does the project satisfy the
statutory minimum density requirements? If
not, can it be revised to do so?
• Not applicable here – project
qualifies
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Summary of AB 1893 Criteria Project Consistency
density or 1/2 of the “Mullen density,”
whichever is lower.20
Site restrictions (Gov. Code §
65589.5(h)(11)(E)).
The project site does not abut a site where
more than one-third of the square footage on
the site has been used, within the past three
years, by a heavy industrial use, or a Title V
industrial use, as those terms are defined in
Section 65913.16.21
Does the project site abut a disqualifying
industrial site?
• No
The Project’s Eligibility for the Protections of AB 1633 and a CEQA Infill Exemption
We first note for informational purposes that the Project is eligible for the protections of AB 1633,
which became effective January 1, 2024, as documented in more detail in the below chart. Under
AB 1633, it is now a violation of the HAA to fail to grant qualifying projects a CEQA exemption,
where there is substantial evidence in the record that the project is eligible for such an exemption.
AB 1633 limits the City’s authority to require analysis that is not legally required and beyond the
limited scope of its discretion.
20“The following densities shall be deemed appropriate to accommodate housing for lower income households: (i) For
an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan area:
sites allowing at least 15 units per acre. (ii) For an unincorporated area in a nonmetropolitan county not included in
clause (i): sites allowing at least 10 units per acre. (iii) For a suburban jurisdiction: sites allowing at least 20 units per
acre. (iv) For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre.” Gov. Code §
65583.2(c)(3)(B).
21 Gov. Code § 65913.16(b): (4) “Heavy industrial use” means a use that is a source, other than a Title V source, as
defined by Section 39053.5 of the Health and Safety Code, that is subject to permitting by a district, as defined in
Section 39025 of the Health and Safety Code,21 pursuant to Division 26 (commencing with Section 39000) of the
Health and Safety Code or the federal Clean Air Act (42 U.S.C. Sec. 7401 et seq.). A use where the only source
permitted by a district is an emergency backup generator, and the source is in compliance with permitted emissions
and operating limits, is not a heavy industrial use. […] (11) “Title V industrial use” means a use that is a Title V
source, as defined in Section 39053.5 of the Health and Safety Code.21
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AB 1633 Eligibility Criteria Project Consistency
[S]ubstantial evidence in the record before the local agency that the housing development
project is not located . . .” in the following areas:22
zone 23 coastal zone.
statewide importance . . . designated
on the maps prepared by the Farmland
Mapping and Monitoring Program of
the Department of Conservation, or
land zoned or designated for
agricultural protection or preservation
by a local ballot measure that was
approved by the voters of that
jurisdiction.”24
farmland of statewide importance by the California
Department of Conservation.25 The Project site is not
zoned or designated for agricultural protection, but
rather is zoned for urban uses and surrounded by
other urban uses.
uses and does not contain wetlands.
Cortese List “or a hazardous waste site
designated by the Department of Toxic
Substances Control,” unless the
Department of Toxic Substances
Control has cleared the site for
residential or residential mixed uses.27
fault zone, “unless the development
complies with applicable seismic
protection building code standards
delineated earthquake fault zone.30
22 Gov. Code § 65589.5.1(a)(1): On a site specified in subparagraphs (A) to (C), inclusive, or subparagraphs (E) to
(K), inclusive, of paragraph (6) of subdivision (a) of Section 65913.4.”
23 Gov. Code § 65913.4(a)(6)(A) (as amended by SB 423 (2023)).
24 Gov. Code § 65913.4(a)(6)(B).
25 See https://maps.conservation.ca.gov/DLRP/CIFF/, last accessed April 13, 2025.
26 Gov. Code § 65913.4(a)(6)(C) (“as defined in the United States Fish and Wildlife Service Manual, Part 660 FW 2
(June 21, 1993)”).
27 Gov. Code § 65913.4(a)(6)(E).
28 California Environmental Protection Agency Cortese List: https://calepa.ca.gov/sitecleanup/corteselist/, last
visited April 12, 2025.
30 See https://usgs.maps.arcgis.com/apps/webappviewer/index.html?id=5a6038b3a1684561a9b0aadf88412fcf, last
accessed April 13, 2025.
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AB 1633 Eligibility Criteria Project Consistency
local building department . . ..”29
subject to inundation by the 1 percent
chance of flood,” unless the project
has been issued a Letter of Map
Revision or flood plain development
permit.31
which is not a special flood hazard area.32
has received a no-rise certification.33
an adopted natural community
conservation plan . . ., habitat
conservation plan . . ., or other adopted
natural resource protection plan.”35
not identified for conservation.
identified as candidate, sensitive, or
species of special status by state or
federal agencies, fully protected
species, or species protected by the
Federal Endangered Species Act . . .,
the California Endangered Species Act
. . ., or the Native Plant Protection Act
. . ..”36
and surrounded by urban uses, and the vacant portion
of the Project site appears to be regularly mowed,
and is fenced. We do not anticipate the Project site
contains such habitat.
easement.”37 easements recorded on the Project site, based on the
Project’s title report.
29 Gov. Code § 65913.4(a)(6)(F).
31 Gov. Code § 65913.4(a)(6)(G).
32 See https://hazards-
fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b5529aa9cd, last accessed
April 13, 2025.
33 Gov. Code § 65913.4(a)(6)(H).
34 See https://hazards-
fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b5529aa9cd, last accessed
April 13, 2025.
35 Gov. Code § 65913.4(a)(6)(I).
36 Gov. Code § 65913.4(a)(6)(J).
37 Gov. Code § 65913.4(a)(6)(K).
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AB 1633 Eligibility Criteria Project Consistency
severity zone, as determined by the
Department of Forestry and Fire
Protection.”38
Fire Hazard Severity Zone within the State
Responsibility Area as determined by CALFire.39
The project’s parcel(s) is legal and located “within an urbanized area 40 and meets one or
the more of the following criteria . . ..”41
distance” of “a high quality transit
corridor,” as defined in Public
Resources Code Section 21155(b), or
“a major transit stop,” as defined in
Pub. Res. Code Section 21064.3.42
qualifies under one or more other criteria.
area”43 qualifies under one or more other criteria.
. . as of the date of the” application’s
submittal.44
A project is proximal an amenity if it
is within:
• .5 mile of “[a] bus station” or “[a]
ferry terminal”; OR
1 mile of “[a] supermarket or grocery
store,” “public park,” “community
center,” “pharmacy or drugstore,”
Community Playing Fields; Grocery Outlet; Barron
Park Elementary School; Cornelis Bol Park; and
likely others. Analysis not required because the
Project qualifies under one or more other criteria –
see row immediately below.
38 Gov. Code § 65589.5.1(a)(1)(B) (“Within a very high fire hazard severity zone, as determined by the Department
of Forestry and Fire Protection pursuant to Section 51178, or within a high or very high fire hazard severity zone as
indicated on maps adopted by the Department of Forestry and Fire Protection pursuant to Section 4202 of the Public
Resources Code.”).
39 See https://osfm.fire.ca.gov/what-we-do/community-wildfire-preparedness-and-mitigation/fire-hazard-severity-
zones, last accessed April 13, 2025.
40 A parcel is within an urbanized area if it meets the definition provided in Public Resources Code Section 21071.
Gov. Code § 65589.5.1(b)(5). The Project site is located in an urbanized area because Palo Alto is a qualifying
incorporated city because its population, when combined with the populations of contiguous cities Menlo Park and
East Palo Alto, is greater than 100,000.
41 Gov. Code § 65589.5.1(a)(2).
42 Gov. Code § 65589.5.1(a)(2)(A).
43 Gov. Code § 65589.5.1(a)(2)(B).
44 Gov. Code § 65589.5.1(a)(2)(C).
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AB 1633 Eligibility Criteria Project Consistency
kindergarten to 12th grade.45
3 sides of a 4 sided project site) is
adjoined by urban uses.46
shown on Google Maps.
The project’s density meets the following criteria
per acre.”47 15 du/ac.
“There is substantial evidence in the record that”
•
exemption”48; AND
• That any categorical exemption
sought is not barred by an
49
32 Urban Infill Exemption, see the discussion below.
We anticipate that the City will find the Project eligible for a Class 32 Infill Exemption, because
it meets the Class 32 Infill Exemption criteria and is not subject to any of the exceptions, as
documented below.
1. The project is consistent with the applicable general plan designation and all applicable
general plan policies as well as with applicable zoning designation and regulations.
45 Gov. Code § 65589.5.1(b)(4).
46 Gov. Code § 65589.5.1(a)(2)(D).
47 Gov. Code § 65589.5.1(a)(3).
48 Gov. Code § 65589.5.1(a)(4)(A)
49 Gov. Code § 65589.5.1(a)(4)(B).
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As revised to proceed under Builder’s Remedy 2.0, the Project is consistent as a matter of law. AB
1893 provides that any project that complies with AB 1893 “shall be deemed consistent, compliant,
and in conformity with an applicable plan, program, policy, ordinance, standard, requirement,
redevelopment plan and implementing instruments, or other similar provision for all purposes.”50
On February 7, 2025, San Jose received a Technical Assistance letter from the Department of
Housing and Community Development (HCD) that says due to AB 1893, lead agencies cannot
rely on subdivision (a) of CEQA Guidelines section 15332 to preclude a project that meets the
definition of “Builder’s Remedy” from utilizing a Class 32 Infill Exemption. Builder’s Remedy
projects that meet all other criteria for a Class 32 Infill Exemption, and for which none of the
exceptions criteria in Section 15300.2 of the CEQA Guidelines apply, are eligible for a Class 32
Infill Exemption.
2. The proposed development occurs within city limits on a project site of no more than five
acres substantially surrounded by urban uses.
The Project Site is approximately 2.61 acres, and is entirely surrounded by urban uses.
3. The project site has no value as a habitat for endangered, rare, or threatened species.
The Project Site is not identified in any regional, state, or federal plans for habitat or conservation.
The Project Site is developed with urban uses and is surrounded by urban development and
significant roadways including El Camino Real, and has no anticipated value as habitat for
threatened, rare or endangered species. The vacant portion of the Project Site is regularly mowed
and is surrounded by other urban development.
4. Approval of the project would not result in any significant effects relating to traffic,
noise, air quality or water quality.
The Project does not entail any unusual methods of construction or particularly impactful use, and
we anticipate that the Project will be found not to cause significant traffic, noise, air quality, or
water quality impacts.
5. The site can be adequately served by all required utilities and public services.
The Project would not propose unusually intensive uses, and will be required to comply with all
local regulations governing the provision of utilities and public services.
Exceptions to Categorical Exemptions 51:
50 Govt. Code §65589.5(f)(1)(D)(iii).
51 CEQA Guidelines § 15300.2.
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1. The project will not have a significant cumulative impact resulting from “successive
projects of the same type in the same place, over time.”52
The Project is a single residential development, and there is no plan to propose “successive”
development on the Project Site. Accordingly, we anticipate the City will conclude that the Project
will not have any new cumulative impacts related to “successive projects of the same type in the
same place, over time.”
2. The project will not “have a significant effect on the environment due to unusual
circumstances.”53
There are no unusual circumstances related to the Project. In determining whether the “unusual
circumstances” exception applies, the only questions are (a) whether there is any substantial
evidence to support the City’s conclusion that the Project does not have unusual features that
distinguish it from other comparable Class 32 infill projects, and (b) whether any project opponents
have shown that “the project will have a significant environmental effect.”54
The Project is a typical infill housing development project and we anticipate that substantial
evidence will demonstrate that the Project will not have a significant effect on the environment.
Further, no opponents have demonstrated that the project “will have” significant environmental
effects.
3. The project will not “result in damage to scenic resources, including but not limited to,
trees, historic buildings, rock outcroppings, or similar resources, within a highway
officially designated as a state scenic highway.”55
The Project has no effect on scenic highways.
4. The project is not “located on a site which is included on any list compiled pursuant to
Section 65962.5 of the Government Code.”56
The Project Site is not listed on the Cortese List and it is not designated by the Department of
Toxic Substances Control as a hazardous waste site.57
52 CEQA Guidelines § 15300.2(b).
53 CEQA Guidelines § 15300.2(c).
54 Walters v. City of Redondo Beach (2016) 1 Cal.App.5th 809, 822-23 (emphasis in the original).
55 CEQA Guidelines § 15300.2(d).
56 CEQA Guidelines § 15300.2(e).
57 California Environmental Protection Agency Cortese List: https://calepa.ca.gov/sitecleanup/corteselist/, last
visited April 12, 2025.
Palo Alto Planning Department
April 25, 2025
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5. The project will not cause a substantial adverse change in the significance of a historical
resource.”58
The Project Site is not a designated as historic. This exception may only be applied to the extent
that designation had already been made on or before the Project’s complete application was
submitted.59
As outlined in this letter, the Project is eligible for AB 1633 and a Class 32 Infill Exemption. The
Applicant would like to move forward with the process to complete CEQA, including any specific
studies required, and look forward to discussing with the City as soon as possible. We appreciate
the City’s attention to this Project.
Sincerely,
HOLLAND & KNIGHT LLP
Genna Yarkin
Chelsea Maclean
58 CEQA Guidelines § 15300.2(f).
59 Gov. Code § 65913.10.
560 Mission Street, Suite 1900 | San Francisco, CA 94105 | T 415.743.6900 | F 415.743.6910
-743-6990
-743-6979
Houston | Jacksonville | Los Angeles | Miami | Nashville | Newport Beach | New York | Orlando | Philadelphia
June 6, 2024
Re: Submission of Formal Development Application Under the “Builder’s Remedy”
Provision of the Housing Accountability Act – 3606 El Camino Real, Palo
Alto, CA
Dear All:
This firm represents Vittoria Management, Inc. (the “Applicant”), on behalf of whom we are
pleased to provide the enclosed formal application for redevelopment of the property at 3606 El
Camino Real (the “Project Site”) in Palo Alto, California (the “City”).1 The project proposes to
redevelop the Project Site with 335 multifamily units (the “Project”), providing high-quality
housing in a contemporary architectural style that will create visual interest and enhance the El
Camino corridor, while contributing to the City’s achievement of the City’s regional housing needs
allocation. As a housing development project, the Project is subject to Senate Bill (“SB”) 330 and
protected by the Housing Accountability Act (“HAA”).2
The purpose of this letter is to transmit the project’s formal planning application. The application
provides the information required by the City’s Preliminary ARB Submittal Requirements
Checklist and Major/Minor Architectural Review Submittal Requirements Checklist, which we
understand to be the City’s requirements for the Project’s formal planning application.
I.SB 330 and the “Builder’s Remedy” Provision of the HAA
Pursuant to SB 330, the Applicant submitted a preliminary application on January 30 2024, with
the information required by Government Code Section 65941.1 and paid the City’s required fee
on February 15, 2024. Accordingly, the Applicant obtained a vested right to develop a housing
1 The Project Site is composed of APNs: 137-08-16, 137-08-88, 137-08-79, 137-08-80, 137-08-81, 137-08-77, 137-
08-70.
2 Gov. Code § 65589.5. The Project qualifies as a housing development project protected by the HAA because the
Project proposes all residential units. Gov. Code § 65589.5(h)(2)(A).
Palo Alto Planning & Development
June 6, 2024
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development project in accordance with the applicable “ordinances, policies, and standards” in
effect as of February 15, 2024, subject to a requirement to submit a formal application within 180
days, or by August 13, 2024.3 The enclosed formal application materials are hereby submitted in
satisfaction of that requirement.
An applicant’s vested rights include a right to proceed under the City’s housing element
compliance status in effect at the time of the submittal of the Project’s SB 330 preliminary
application.4 The compliance status of a jurisdiction’s housing element is determined by the
Department of Housing and Community Development (“HCD”) and “HCD’s determination of
substantial compliance with the Housing Element [l]aw, or lack thereof, is entitled to deference.”5
As confirmed by HCD, when a preliminary application submittal “occurs at a time when the
jurisdiction does not have a compliant housing element, any potential benefits afforded to the
applicant as a result of the jurisdiction’s noncompliant status . . . remain throughout the entitlement
process even if the jurisdiction subsequently achieves compliance during the entitlement
process.”6
Our cover letter for the Project’s SB 330 preliminary application explains in detail why the City’s
housing element was not in substantial compliance with Housing Element law at the time of the
Project’s SB 330 preliminary application submittal. Additionally, the Applicant submitted an SB
330 preliminary application prior to the City’s adoption of the City’s housing element on April 15,
2024 and HCD has not yet certified the adopted housing element. Therefore, Applicant’s SB 330
preliminary application vested against the City’s non-compliant housing element and the City must
process Applicant’s application for a housing development project regardless of whether the
Project complies with the City’s zoning or general plan.7
The proposal of a housing development project that does not comply with a jurisdiction’s
applicable general plan designation or zoning, and which is made while a jurisdiction’s housing
element is not in substantial compliance with Housing Element law, is informally known as the
“Builder’s Remedy.” As explained in our prior letter, the City is prohibited from disapproving a
qualifying Builder’s Remedy project “on the grounds it does not comply with the municipality’s
zoning and general plan.”8 To qualify as a Builder’s Remedy project, the project must include
3 Gov. Code § 65589.5(o)(1); § 65941.1(d).
4 California Housing Defense Fund v. City of La Cañada Flintridge, Los Angeles County Superior Court Case No.
23STPC02614, Order on Petitions For Writ of Mandate and Complaints for Declaratory Relief (“Builder’s Remedy
Order”), (Mar. 4, 2024), at 15-16.
5 Id. at 19 (citations omitted).
6 See HCD, “3030 Nebraska Avenue, Santa Monica – Letter of Technical Assistance” (Oct. 5, 2022).
Available at https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/HAU/santa-monica-TA-
100522.pdf.
7 California Housing Defense Fund, Builder’s Remedy Order, at 33 (holding that “the City is required by law to
process the application pursuant to the Builder’s Remedy provision of the HAA” and that is is an abuse of discretion
to find “that the Builder’s Remedy does not apply”).
8 California Housing Defense Fund, Builder’s Remedy Order, at 1; Gov. Code § 65589.5(d).
Palo Alto Planning & Development
June 6, 2024
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housing “for very low, low-, or moderate-income households,” at the statutorily prescribed levels.9
For purposes of the HAA, housing “for very low, low-, or moderate-income households” includes
projects in which at least 20% of the units are rented at affordable rents to lower-income
households.10
Here, the Project will reserve 20% of the Project’s units as affordable to lower income households
Therefore, because the Project will provide the requisite levels of affordable units and the City’s
housing element was out of compliance at the time the Project’s SB 330 preliminary application
was submitted, the City may not deny the Project for noncompliance with the existing general plan
designation or zoning. For this reason, the Project is not required to, and is not designed to comply
in all respects with the Project site’s zoning or general plan designations. The Project design may
continue to evolve throughout the processing of the Project’s application because a project’s vested
rights are maintained as long as “the number of residential units or square footage of construction”
does not change by more than 20%.11
II. State Density Bonus Law – Right Reserved
By providing 20% of the Project’s units affordable to lower income households, the Project is
entitled to the benefits of the State Density Bonus Law (“SDBL”), Gov. Code § 65915. This letter
reserves the right to apply for certain benefits under the SDBL at a later date. Pursuant to the
SDBL, the Project’s affordability level entitles the Project to all of the following separate
categories of benefits:
• (1) A 35% density bonus over the base density;
• (2) Two mandatory concessions or incentives;
• (3) Any required physical waivers of development standards to accommodate the
Project; and
• (4) Applicable mandatory residential parking standards.
Because the Project is a qualifying Builder’s Remedy project, the Project is not limited by existing
zoning or general plan standards and the City must process the Project’s application consistent
with the requirements under state housing law.12 Although the Project is not required to exercise
the Project’s right to a density bonus, the Applicant reserves the right to apply for density bonus
units, up to the maximum, and other protections for which it is eligible. The Project is not required
to utilize a density bonus in order to qualify for incentives, concessions, waivers, and parking
reductions. Applicant reserves the right to identify and apply for SDBL concessions or incentives,
waivers, and parking reductions at a later date.
9 Gov. Code § 65589.5(d).
10 Gov. Code § 65589.5(h)(3).
11 Gov. Code § 655895(o)(2)(E).
12 Gov. Code § 65589.5(f)(1) (any objective policies, standards, or conditions applied to the project must “be applied
to facilitate and accommodate development at the density . . . proposed by the development”).
Palo Alto Planning & Development
June 6, 2024
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Please note that the City’s authority to review the “completeness” of the Project’s formal
development application is strictly limited to determining whether the application provided the
material contained on the City’s official submittal requirements checklist(s), as they existed at the
time of submittal.13 Additionally, “[i]n any subsequent review of the application determined to be
incomplete, the local agency shall not request the applicant to provide any new information that
was not stated in the initial list of items that were not complete.”14 We look forward to receiving
the City’s response to the enclosed formal application and welcome further advisory comments in
addition to the completeness determination.
Thank you for your attention to this matter, we look forward to working with the City on bringing
this project to fruition.
Sincerely yours,
HOLLAND & KNIGHT LLP
Genna Yarkin
Chelsea Maclean
13 Gov. Code § 65943(a); see also Gov. Code §§ 65940, 65941, 65941.5.
14 Gov. Code § 65943(a).
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@paloalto.gov
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Project Plans
In order to reduce paper consumption, a limited number of hard copy project plans are provided to
Councilmembers for their review. The same plans are available to the public, at all hours of the day,
via the following online resources.
Directions to review Project plans and environmental documents online:
1. Go to: bit.ly/PApendingprojects
2. Scroll down to find “3606 El Camino Real” and click the address link
3. On this project-specific webpage you will find a link to the project plans and other important
information
Direct Link to Project Webpage:
https://www.paloalto.gov/Departments/Planning-Development-Services/Current-Planning/Projects/3606-El-
Camino-Real
Materials Boards:
Color and material boards will be available to view in chambers during the hearing.
Item No. 8. Page 1 of 2
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City Council
Supplemental Report
From: Jonathan Lait, Planning and Development Services Director
Meeting Date: April 13, 2026
Item Number: 8
Report #:2604-6226
TITLE
PUBLIC HEARING / QUASI-JUDICIAL. 3606 El Camino Real [24PLN-00162 & 25PLN-00243]:
Request for Approval of Applications for Major Architectural Review and Vesting Tentative Map
to Merge Seven Existing Parcels to Create a 113,907-Square-Foot Parcel and to Construct a
Seven-Story, Multi-Family Residential Housing Development Project with 321 Units, Thirteen
Percent of Which Would be Provided at a Rate Affordable to Low Income. The Project is
Proposed in Accordance with Builder’s Remedy (California Government Code Section
65589.5(d)(5)). A Senate Bill 330 Pre-Application was Filed on February 15, 2024. CEQA Status:
Exempt Pursuant to Assembly Bill 130 (Public Resources Code Section 21080.66).
RECOMMENDATION
Staff recommends that Council consider the additional information provided in this report,
including the revised Draft Record of Land Use Action.
BACKGROUND
This supplemental memo transmits an updated Attachment B: Draft Record of Land Use Action,
reflecting revised stormwater-related conditions of approval and ensuring consistency between
materials submitted to the City. Following agenda publication, staff coordinated with the
applicant to address outstanding drainage issues associated with the Vesting Tentative Map
(VTM). Due to the expedited timelines under Assembly Bill 130, there was insufficient time to
fully resolve the proposed stormwater infrastructure during project review.
The applicant‘s proposed stormwater improvements caused concerns for staff over increased
public maintenance burdens. In February 2026, the applicant coordinated with City staff to
resolve several of these concerns. Those updates are reflected in the Architectural Plan set
submitted on February 26, 2026, but are not included in the February 3, 2026, VTM plans.
Accordingly, conditions of approval have been incorporated into Section 8 of the Revised
Record of Land Use Action to require that the Final Map reflect the revisions shown in the most
Item No. 8. Page 2 of 2
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recent Architectural Review Plans as well as additional outstanding items related to off-site
drainage improvements.
ATTACHMENTS
APPROVED BY:
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DRAFT ACTION NO. 2026-__
RECORD OF THE COUNCIL OF THE CITY OF PALO ALTO LAND USE ACTION
FOR 3606 EL CAMINO REAL: MAJOR ARCHITECTURAL REVIEW AND VESTING TENTATIVE MAP
[24PLN-00162 & 25PLN-00243]
On _________, 2026, the City Council of the City of Palo Alto (“City Council”) approved a
Major Architectural Review application and Vesting Tentative Map for development of 321
residential rental units (“the project”). In approving the application, Council makes the
following findings, determinations, and declarations:
SECTION 1. Background.
A. On February 15, 2024, Camino Real Development LLC & Kendall Investors,
LLC filed a compliant pre-application in accordance with Senate Bill (SB) 330 and with California
Government Code Section 65589.5(d)(5) (also known as Builder’s Remedy).
B. On June 10, 2024, Camino Real Development LLC & Kendall Investors filed an
Architectural Review application (24PLN-00162) for construction of a 321 rental unit residential
project. In addition, Camino Real Development LLC & Kendall Investors filed an application for a
Vesting Tentative Map (25PLN-00243) on September 9, 2025, to merge seven existing lots to
create a single resulting 113,907-square-foot parcel (2.62 acres). The project includes 284 base
units and 37 density bonus units, for a total of 321 units, as well as the following density bonus
waivers and concessions in accordance with State Density Bonus Law, and additional protections
as a “builder’s remedy project,” under AB 1893:
Waiver 1: Build-to-lines (90% of frontage built to setbacks where a maximum
50% along El Camino Real is required)
Waiver 2: Upper Story Step Back (None proposed where a 10-foot step-back
above 55 feet in height is required)
Waiver 3: Lot Coverage (83% where maximum 80% is allowed)
Waiver 4: Rear setback (11 feet - 15 feet where a minimum 16 feet is required)
Waiver 5: Rear and Side Daylight Plane (None provided where 10 feet at lot
line then 45-degree angle is required)
Waiver 6: Housing typologies (More than two-acre lots are required to
provide a minimum of three housing types)
C. The project site is comprised of seven existing lots: APN No. 137-08-088,
approximately 10,838 square feet, developed with a commercial use; APN No. 137-08-016,
approximately 5,199 square feet, an undeveloped parcel; APN No. 137-08-079, approximately
10,194 square feet, developed with a commercial use; APN No. 137-08-080, approximately
28,350 square feet, an undeveloped parcel; APN No. 137-08-077, approximately 38,058 square
feet, developed with a multi-family residential use; APN No. 137-08-070, approximately 5,103
square feet, developed with a multi-family residential use; APN No. 137-08-081, approximately
2
16,275 square feet, developed with a commercial and residential use. Adjacent uses include a
mix of commercial and low-intensity, one-story and two-story buildings, as well as low density
residential uses surrounded by surface parking.
D. Following staff review, the Architectural Review Board held a duly noticed
public hearing to review the Major Architectural Review application at hearing on October 16,
2025, to provide feedback on the design.
E. Following staff review, the Planning and Transportation Commission
reviewed the Vesting Tentative Map and recommended denial on February 11, 2026, with
Council to consider the following:
Project and cumulative traffic safety analysis;
Sidewalk easements;
Relocating ingress/egress to improve pedestrian and bicycle safety and reduce
congestion near El Camino Real intersections; and
Incorporating portions of the site for a bike path.
F. On ___________, 2026 the City Council held a duly noticed public hearing at
which evidence was considered, and all persons were afforded an opportunity to be heard in
accordance with the City Council’s policies and procedures.
G. The project site includes parcels in the City’s 2023-2031 Housing Element
Site Inventory, with a projected capacity of 6 very low income units, 6 low income units, 8
moderate income units, and 17 above-moderate income units. The project will provide 37 low
income units and 284 above-moderate income units. Following approval of the project, the
remaining sites in the Site Inventory will be insufficient to meet the remaining Regional Housing
Needs Assessment (RHNA) for moderate income units.
H. Including the proposed project, the remaining RHNA and remaining capacity
at each income level will be approximately:
Lower Moderate Above Moderate
Remaining RHNA 1,957 899 21
RHNA Credits 598 182 515
Remaining Site
Inventory Capacity 1,825 614 1,902
Surplus/Deficit 466 -103 2,396
I. In accordance with Government Code Section 65863, the City shall, within
180 days, identify and make available additional adequate sites to accommodate the remaining
RHNA at the moderate income level.
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SECTION 2. Environmental Review. The City, as the lead agency for the Project, has determined
the project is exempt from California Environmental Quality Act (CEQA) in accordance with AB
130 [Public Resources Code section 21080.66]. Documentation to support the streamlined
review is available as part of the public record on file with the Planning and Development
Services Division.
Section 3. Architectural Review Findings. In order to make a recommendation of approval, the
project must comply with the following Findings for Architectural Review as required in Chapter
18.76.020 of the PAMC.
1. The design is consistent with applicable provisions of the Palo Alto Comprehensive Plan,
Zoning Code, coordinated area plans (including compatibility requirements), and any
relevant design guides.
A summary of the project’s consistency with the Comprehensive Plan is provided in this
table. Because the project is a “builder’s remedy project,” as defined in Gov. Code
section 65589.5(h)(11), and in accordance with Gov. Code section 65589.5(f)(6)(A), the
project is required to comply only with objective, quantifiable, written development
standards, conditions, and policies that would have applied to the project had it been
proposed on a site with a general plan designation and zoning classification that allow
the density and unit type proposed by the applicant. Moreover, in accordance with Gov.
Code section 65589.5(f)(6)(D)(iii), a project that complies with such objective standards,
conditions, and policies “shall be deemed consistent, compliant, and in conformity with
an applicable plan, program, policy, ordinance, standard, requirement, redevelopment
plan and implementing instruments, or other similar provision for all purposes.”
Comp Plan Goals and Policies How project adheres or does not adhere to
Comp Plan
The Comprehensive Plan land use designations
for the project site are Service Commercial
(CS), Neighborhood Commercial (CN), and
Multiple-Family Residential (MF) which
allow multifamily housing in specific locations.
The project site includes seven parcels with
varying Comprehensive Plan land use
designations, including Service Commercial,
Neighborhood Commercial, and Multiple-
Family Residential designations. Four of the
seven parcels on which the proposed project
would be located are identified as housing
inventory sites. The project adheres to the
Comprehensive Plan by providing housing on
these opportunity sites. The proposed multi-
family use is allowed within this land use
designation.
Housing Element
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Comp Plan Goals and Policies How project adheres or does not adhere to
Comp Plan
Policy 4.3 Implement development standards,
objective design standards, and architectural
and green building standards that encourage
new high-quality rental and ownership
housing.
The project complies with the implemented
standards except where requests for waivers or
concessions in accordance with state density
bonus law is provided. The project provides the
necessary upgrades to infrastructure on the
site to provide new high-quality rental
units. The project complies with all required
green building requirements in accordance
with state law and the city’s local reach code.
Land Use and Community Design Element
Goal L-1 A compact and resilient city providing
residents and visitors with attractive
neighborhoods, work places, shopping districts,
public facilities and open spaces.
The project redevelops existing developed
parcels and provides an attractive development
that is generally consistent with the City’s
design criteria.
Policy L-1.3: Infill development in the urban
service area should be compatible with its
surroundings and the overall scale and
character of the city to ensure a compact,
efficient development pattern.
The project is an urban infill development
proposal in the urban service area of the city.
Policy L-1.4: Commit to creating an inventory
of below market rate housing for purchase and
rental.
The proposed residential project includes 321
rental units, and 13 percent of the base 284
units (excluding density bonus units) would be
provided at a rate affordable to low-income
households or below. This would add 37 low
income rental units to the City’s BMR housing
stock.
Goal L-2 An enhanced sense of “community”
with development designed to foster public
life, meet citywide needs and embrace the
principles of sustainability.
The project is designed to comply with
CALGreen Tier 2 requirements that incorporate
sustainable design, construction, and
operational requirements to reduce energy and
water operational costs and in increase indoor
air quality for building owners and occupants.
Policy L-2.2 Enhance connections between
commercial and mixed use centers and the
surrounding residential neighborhoods by
promoting walkable and bikeable connections
and a diverse range of retail and services that
caters to the daily needs of residents.
The project site is located on and adjacent to El
Camino Real, a local serving and regional
serving corridor, defined by a mix of
commercial uses and housing. Caltrans recently
installed Class III and Class IV bike lanes, which
run along the project’s frontage on El Camino
Real. Residents would be able to utilize these
connections to other surrounding areas.
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Comp Plan Goals and Policies How project adheres or does not adhere to
Comp Plan
Goal L-6: Well-designed buildings that create
coherent development patterns and enhance
city streets.
The project frontage along El Camino Real
provides a sidewalk and retains the existing
four street trees. Alongside Matadero Avenue,
the project proposes two new street trees,
alongside Kendall Avenue five new street trees,
and four new trees alongside El Camino Real,
for an inviting streetscape. The project includes
high quality materials such as brick, wood, and
stucco that aid in creating a cohesive design.
Policy L-9.2 Encourage development that
creatively integrates parking into the project,
including by locating it behind buildings or
underground wherever possible, or by
providing for shared use of parking areas.
Encourage other alternatives to surface parking
lots that minimize the amount of land devoted
to parking while still maintaining safe streets,
street trees, a vibrant local economy and
sufficient parking to meet demand.
Parking would be screened behind the first
floor amenity spaces alongside El Camino Real
with the parking garage entrance located along
Matadero Avenue and Kendall Avenue. Further,
391 parking spaces would be provided on-site
exceeding the El Camino Real focus area
parking requirements.
Transportation Element
Policy T-3.7 Encourage pedestrian-friendly
design features such as sidewalks, street trees,
on-street parking, gathering spaces, gardens,
outdoor furniture, art and interesting
architectural details.
The project includes direct connections to the
sidewalk that help to activate the frontage
along El Camino Real in addition to new street
trees and plantings along Matadero Avenue,
Kendall Avenue, and El Camino Real.
Policy T-3.9 Support citywide sustainability
efforts by preserving and enhancing the tree
canopy where feasible within the public right-
of-way, consistent with the Urban Forest
Management Plan, as amended.
The project meets the tree canopy replacement
requirements through on-site plantings. The
project includes removal of 31 trees and
replaces with 129 trees, which are proposed to
be located along property lines, in the right of
way, and within open space areas.
The South El Camino Real Design Guidelines are applicable to the project, to the extent
that the standards are objective, and the site is located within the Triangle Area
Pedestrian Node. The project is consistent with the Guidelines, below is an analysis of
the applicable guidelines:
3.1.1 Effective Sidewalk Width:
Create a 12-foot effective sidewalk width
along El Camino Real
The project proposes a 12-foot effective
sidewalk width.
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3.1.2 Sidewalk Setback Design:
The design of the sidewalk setback should
create an urban “downtown” character.
The proposed sidewalk setback includes
areas for short-term bicycle parking and
architectural wall lights.
3.1.3 Build to lines:
Buildings should be built up to the sidewalk
to reinforce the definition and importance of
the street.
The project provides 90% built to the
setback while still providing the effective 12-
foot sidewalk width.
3.1.5 Minimum Height:
Buildings should have a minimum height of
25 feet in order to provide presence along El
Camino Real.
The project is 82 feet in height to the
parapets.
3.3.1 Usable Amenities:
Landscape and hardscape features should
not just be visually appealing, but also
function as open space amenities to be used
and enjoyed.
The project includes outdoor seating areas,
dining areas, and one pool.
4.1.8 Expression of Use:
Building forms should be articulated as an
expression of the building use.
The project has been revised to add
additional definition to the two-story
residential entry area at the building’s
corner. The balconies also provide visible
private outdoor space, identifying the
residential uses.
4.2.1 Relationship of Entries to the Street:
Buildings should have entries directly
accessible and visible from El Camino Real.
The building has a lobby facing El Camino
Real. The leasing entrance facing Matadero
Avenue and secondary entrance alongside
Kendall Avenue are visible from El Camino
Real.
4.3.6 Design Consistency on All Facades:
All exposed sides of a building should be
designed with the same level of care and
integrity.
All sides of the building use the same variety
of materials and level of detail. They are also
articulated for visual interest and to reduce
massing.
4.4.1 Amenities:
Building design should offer amenities to
users and the public such as protection from
the elements and places for people to gather
or retreat.
The project provides a number of public and
private gathering areas.
4.5.1 Flat Roofs and Parapets Encouraged.
Flat roofs with parapets are strongly
encouraged.
The proposed building has a flat roof with
parapet design.
4.8.1 Mix of Materials:
Juxtaposition of contrasting materials can
create interest when carefully integrated.
This project includes stucco, cast stone,
marble, brick, glass, and metal in a
composed design.
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2. The project has a unified and coherent design, that:
a. creates an internal sense of order and desirable environment for occupants,
visitors, and the general community,
b. preserves, respects and integrates existing natural features that contribute
positively to the site and the historic character including historic resources of the
area when relevant,
c. is consistent with the context-based design criteria of the applicable zone
district,
d. provides harmonious transitions in scale, mass and character to adjacent land
uses and land use designations,
e. enhances living conditions on the site (if it includes residential uses) and in
adjacent residential areas.
The project is consistent with Finding #2 because:
The project is comprised of various residential amenity spaces at the first floor, third floor, and
seventh floor and offers short-term bike racks for visitors and well as long-term bike lockers for
residents. There is pedestrian access adjacent to El Camino Real located on Matadero Avenue
and Kendall Avenue to promote walkability and connectivity. Cars enter the garage on
Matadero Avenue and Kendall Avenue as required per the objective standards. The pedestrian
walkways are paved with attractive materials and landscaped. The project proposes to
construct a building that is generally taller than the immediately surrounding buildings.
The proposed project is consistent with the findings to provide high quality materials and
finishes in a neutral color palette. The building will have residential amenity spaces on the first
floor with a majority of those spaces utilizing glazing, which helps to engage the sidewalk.
While the project at 82 feet in height exceeds surrounding development, the project complies
with the height limits within the El Camino Real Focus Area and deviates from the objective
standards in a manner consistent with state law.
3. The design is of high aesthetic quality, using high quality,
integrated materials and appropriate construction techniques, and incorporating
textures, colors, and other details that are compatible with and enhance the surrounding
area.
The project is consistent with Finding #3 because:
The project proposes a contemporary style that is recognizable along the El Camino corridor
overall and aligns with the recent residential development to the north of the project site. The
project uses materials such as stucco, cast stone, marble, brick, glass, and metal railings on the
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balconies and metal awnings. As conditioned, the stucco surfaces will be a smooth finish
texture. The proposed colors are neutral and are compatible with surrounding color schemes.
The project is located within an area subject to the adopted El Camino Design Guidelines and
South El Camino Real Guidelines and is consistent with objective standards set forth in these
guidelines.
4. The design is functional, allowing for ease and safety of pedestrian and bicycle traffic
and providing for elements that support the building’s necessary operations
(e.g. convenient vehicle access to property and utilities, appropriate arrangement and
amount of open space and integrated signage, if applicable, etc.).
The project is consistent with Finding #4 because:
The design of the new building includes wider sidewalks on El Camino Real, new sidewalks
where none currently exist on Matadero and Kendall Avenues, and does not provide any new
curb cuts along El Camino Real, which would have otherwise created additional points of
conflict with the existing bicycles lanes. The entrances to the parking garage are consistent with
both objective standards set forth in the City’s municipal code Ch. 18.24 as well as best
practices for roadway engineering design. Introducing or expanding curb cuts directly along an
arterial corridor, particularly a state freeway, creates additional turning conflicts, reduces traffic
flow efficiency, and increases safety risks for cyclists and motorists, especially given the newly
installed bicycle lanes along the project’s El Camino Real frontage. Additionally, there will be
280 bike lockers and, as conditioned, short-term bike rack spaces provided in accordance with
California Green Building Standards Code. By providing increased bicycle infrastructure, the
project will improve existing conditions. There are both common and private open spaces
available, including private decks for a majority of rental units.
5. The landscape design complements and enhances the building design and its
surroundings, is appropriate to the site’s functions, and utilizes to the extent practical,
regional indigenous drought resistant plant material capable of providing desirable
habitat that can be appropriately maintained.
The project is consistent with Finding #5 because:
The project will provide a variety of drought-tolerant planting, including plantings selected from
a California native palette. The selected varieties of trees would provide appropriate habitat for
wildlife as a part of a bigger neighborhood and community wide system. Additional landscaping
is provided on the terraces of the building.
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6. The project incorporates design principles that achieve sustainability in areas related to
energy efficiency, water conservation, building materials, landscaping, and site
planning.
The project is consistent with Finding #6 because:
In accordance with the City’s Green Building Regulations, the project will satisfy the
requirements for CALGreen Mandatory + Tier 2. This is demonstrated on the GB sheets in the
plan set.
SECTION 4. Vesting Tentative Map Findings. A legislative body of a city shall deny approval of a
Subdivision Map, if it makes any of the following findings (California Government Code Section
66474). The City Council cannot make these findings for the following reasons:
1. That the proposed map is not consistent with applicable general and specific plans as
specified in Section 65451:
There is no adopted specific plan for this project site. The site is consistent with the
Comprehensive Plan as described below.
2. That the design or improvement of the proposed subdivision is not consistent with
applicable general and specific plans:
There is no adopted specific plan for this project site. The proposed Vesting Tentative Map and
related improvements is consistent with the Comprehensive Plan in that it facilitates housing
development on a site designated for multi-family use within the urban services area,
consistent with Goal 2 of the Housing Element and Goal L1.2 of the Land Use Element. The
project includes 321 Units, 37 of which would be provided at a rate affordable to low income.
The project improves the city’s jobs housing imbalance, consistent with the Transportation
Element’s goals and policies. Because the project is a “builder’s remedy project,” as defined in
Gov. Code section 65589.5(h)(11), and in accordance with Gov. Code section 65589.5(f)(6)(A),
the project is required to comply only with objective, quantifiable, written development
standards, conditions, and policies that would have applied to the project had it been proposed
on a site with a general plan designation and zoning classification that allow the density and
unit type proposed by the applicant. Moreover, in accordance with Gov. Code section
65589.5(f)(6)(D)(iii), a project that complies with such objective standards, conditions, and
policies “shall be deemed consistent, compliant, and in conformity with an applicable plan,
program, policy, ordinance, standard, requirement, redevelopment plan and implementing
instruments, or other similar provision for all purposes.”
3. That the site is not physically suitable for the type of development:
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The Project site is suitable for multi-family residential development in that the majority of the
parcels are identified as Housing Inventory Sites in the Housing Element. The project is also
located within the City’s El Camino Real Focus Area, an area identified for high density housing
within the City. The proposed parcel meets the minimum code requirements for the CN, CS,
RM-30, and RM-40 zone districts with respect to lot area, width, and depth. The proposed
number of apartment units created on the resulting parcel complies with the applicable
densities set forth in the land use element and zoning code, consistent with the focus area
standards. In addition, as noted above, the project is proposed pursuant to the “builder’s
remedy” of the Housing Accountability Act (Government Code section 65589.5) and is
consistent with the standards set forth therein.
4. That the site is not physically suitable for the proposed density of development:
The proposed improvements include a total of 321 multi-family residential units and results in
128 dwelling units per acre (DU/AC) across the resulting parcel. Because the site area is
comprised of several lots, there are varying zoning designations across these lots, including
portions zoned CN, CS, RM-30, and RM-40. In December 2023, the City Council adopted the El
Camino Real Focus Area which established a local alternative to State Density Bonus Law along
four properties on El Camino Real between Page Mill Road and Matadero Avenue. In
accordance with the Housing Element Implementation, several additional sites were added to
the El Camino Real Focus Area in July 2025, including the subject property.
While the zoning code does not set a maximum density for projects on El Camino Real, the
improvements are consistent with the density, floor area, and height allowances for sites within
the Focus Area. Therefore, the project is physically suitable for the parcel. In addition, the
project is proposed pursuant to the “builder’s remedy” of the Housing Accountability Act
(Government Code section 65589.5) and is consistent with the densities permitted therein.
5. That the design of the subdivision or the proposed improvements are likely to cause
substantial environmental damage or substantially and avoidably injure fish or wildlife
or their habitat:
The project is located within the built environment that does not contain quality habitat for fish
or other wildlife on the site or within the vicinity of the site. The nearest stream is a portion of
Matadero Creek approximately 300 feet northwest from the project site. The adopted Palo Alto
2030 Comprehensive Plan includes Map N-1, which identified sensitive animal and plant species
within the Palo Alto quadrangle, a large geographic area that includes the urban portions along
the bay and within the foothills, based on information in the California natural Diversity
Database (CNDDB). Based on this map, and the urban nature of the site, the subject property
does not contain any habitat for endangered, rare, or threatened species.
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6. That the design of the subdivision or type of improvements is likely to cause serious
public health problems:
The record indicates that insufficient information has been provided to fully demonstrate that
the project would not create safety risks for bicyclists and pedestrians, including along safe
routes to school. Specifically, a traffic analysis has not yet been conducted for the site.
Cumulative impacts from proposed projects in the vicinity, including the project at 3400 El
Camino Real across Matadero Avenue, have not been evaluated.
Notwithstanding this inconsistency, the deviation is permitted under applicable State law,
which limits the City’s ability to deny based on such impacts. The proposed multi-family use
would not include use or storage of hazardous materials and the use is located within the urban
environment adjacent to other commercial uses. The site is not located on a hazardous waste
site pursuant to government code 65962.5. However, a portion of the site was previously a
gasoline service station that had its underground storage tanks removed and issued a Fuel Leak
Site Case Closure letter on July 23, 1997. Additional cleanup of the site for residential uses per
standard requirements will be included in the conditions of approval for the proposed
improvements.
7. That the design of the subdivision or the type of improvements will conflict with
easements, acquired by the public at large, for access through or use of, property within
the proposed subdivision. In this connection, the governing body may approve a map if
it finds that alternate easements, for access or for use, will be provided, and that these
will be substantially equivalent to ones previously acquired by the public. This subsection
shall apply only to easements of record or to easements established by judgment of a
court of competent jurisdiction and no authority is hereby granted to a legislative body
to determine that the public at large has acquired easements for access through or use
of property within the proposed subdivision.
There are no public access easements over the property currently. Therefore, the design of the
subdivision will not conflict with any public easements for access through, or use of, the
property. New public utility easements will be provided to existing and proposed electrical
utilities as part of this subdivision map as required in accordance with City of Palo Alto Utilities
standards. New public access easements will be provided to provide the 12-foot effective
sidewalk width along El Camino Real, consistent with project plans and City requirements.
SECTION 5. Vesting Tentative Map Approval Granted. Vesting Tentative Map Approval is filed
and processed in accordance to PAMC Section 21.13.020 and granted by the City Council under
PAMC Sections 21.12 and 21.20 and the California Government Code Section 66474, subject to
the conditions of approval in Section 8 of this Record of Land Use Action.
SECTION 6. Final Map. The Final Map submitted for review and approval by the City Council
shall be in substantial conformance with the Vesting Tentative Map prepared by Kier+Wright
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titled “VESTING TENTATIVE MAP” consisting of eleven pages, dated and submitted February 3,
2026, except as modified to incorporate the conditions of approval in Section 8. A copy of the
Vesting Tentative Map is on file in the Department of Planning and Development Services,
Current Planning Division. Prior to the expiration of the Vesting Tentative Map approval, the
subdivider shall cause the subdivision or any part thereof to be surveyed, and a Final Map, as
specified in Chapter 21.08, to be prepared in conformance with the Vesting Tentative Map as
conditionally approved, and in compliance with the provisions of the Subdivision Map Act and
PAMC Title 21 and submitted to the City Engineer (PAMC Section 21.16.010[a]).
SECTION 7. Conditions of Approval Architectural Review.
Planning
1. CONFORMANCE WITH PLANS. Construction and development shall be in substantial
conformance with the approved plans entitled, "3606 El Camino Real – Major Architecture
Review” uploaded to the Palo Alto Online Permitting Services Citizen Portal on February 2,
2026, as modified by these conditions of approval.
2. BUILDING PERMIT. Apply for a building permit and meet any and all conditions of provided
for in this letter. A copy of this cover letter and conditions of approval shall be printed on
the second page of the plans submitted for building permit.
3. BELOW MARKET RATE (BMR) HOUSING. This project is proposed as a Builder’s Remedy
project, as defined in AB 1893, and is providing thirteen percent of the proposed 284 base
units at prices affordable to lower income households. This also represents an alternative
means of compliance with the City’s inclusionary housing requirement stated in Palo Alto
Municipal Code Chapter 16.65. The applicant shall execute and record a BMR regulatory
agreement in a form satisfactory to the City Attorney. The project shall conform to the
approved regulatory agreement, which shall be recorded prior to issuance of building
permit or final map, whichever occurs first. All BMR units constructed under this condition
shall be in conformance with the City’s BMR Program rules and regulations, as modified by
the concession granted pursuant to State Density Bonus Law regarding unit distribution.
Failure to comply with the timing of this condition and any adopted BMR Program rules
and regulations shall not waive its later enforcement.
4. RENTER PROTECTIONS. The project is subject to the renter protection requirements set
forth in PAMC Section 9.68.060 for no fault evictions for rental properties with more than
10 units. This includes either rental fee waiver for the last month or relocation assistance
as detailed in the municipal code. Notification requirements in accordance with the code is
required. Documentation showing compliance with these code requirements must be
provided to the project planner prior to issuance of a demolition/deconstruction permit.
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5. PROJECT MODIFICATIONS. All modifications to the approved project shall be submitted for
review and approval prior to construction. If during the Building Permit review and
construction phase, the project is modified by the applicant, it is the responsibility of the
applicant to contact the Planning Division/project planner directly to obtain approval of the
project modification.
6. LANDSCAPE PLAN. Plantings shall be installed in accordance with the approved plan set
prior to occupancy and shall be permanently maintained and replaced as necessary.
7. STANDARD CONDITION FOR VAPOR INTRUSION. For projects which are known to be subject
to risk of vapor intrusion, the applicant shall assess site conditions to determine both the
nature and extent of contamination. If contamination at the site exceeds the most current
environmental screening levels (ESLs) identified by the Regional Water Quality Control
Board (RWQCB) for volatile organic compounds, the applicant shall prepare and submit a
Site Management and Contingency Plan (SMCP) to either the Department of Toxic
Substances Control (DTSC), RWQCB, or the County of Santa Clara Department of
Environmental Health for approval. The SMCP shall include details regarding the pending
development and propose remediation and/or mitigation to address any environmental risk
identified in the site assessment. The applicant shall agree to and implement all
recommendations of the reviewing regulatory agency approving the SMCP in order to
reduce the exposure of future occupants to vapor intrusion. A copy of the approved SMCP
shall be submitted to the Director of Planning prior to issuance of a building permit. If the
reviewing agency requires that a vapor intrusion barrier system be installed, the VIMs shall
be document in the building permit plan set prior to issuance of the building permit.
Post construction indoor air monitoring shall be conducted for any VIMS systems and shall
comply with the specific recommendations set forth by the regulatory agency approving the
SMCP.
8. STANDARD CONDITION NESTING BIRD SURVEY. Vegetation or tree removal shall be
prohibited during the general avian nesting season (February 1 – August 31), if feasible. If
nesting season avoidance is not feasible, the applicant shall retain a qualified biologist, as
approved by the City of Palo Alto, to conduct a preconstruction nesting bird survey to
determine the presence/absence, location, and activity status of any active nests on or
adjacent to the project site no more than 14 days prior to scheduled vegetation clearance
and/or demolition activities. If nesting birds are found to be present, a suitable buffer
(typically a minimum buffer of 50 feet for passerines and a minimum buffer of 250 feet for
raptors) as determined appropriate by the biologist, shall be established around such active
nests and no construction shall be allowed within the buffer areas until a qualified biologist
has determined that the nest is no longer active (i.e., the nestlings have fledged and are no
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longer reliant on the nest). A report documenting any data recovered during monitoring
shall be prepared by a qualified biologist and submitted to the Director of Planning prior to
final planning inspection.
9. CULTURAL SENSITIVITY TRAINING. Prior to issuance of any grading permit, the project
applicant shall be required to submit evidence that a Cultural Awareness Training program
has been provided to construction personnel. The training shall be facilitated by a qualified
archaeologist in collaboration with a Native American representative registered with the
Native American Heritage Commission for the City of Palo Alto and that is traditionally and
culturally affiliated with the geographic area as described in Public Resources Code Section
21080.3.
10. SUB-SURFACE MONITORING. Prior to issuance of any tree removal, grading, demolition,
and/or building permits or activities, the applicant shall notify the Director of Planning, of
grading and construction dates and activities that require a qualified archeologist and
Native American monitor to be present on the project site. The City shall then notify the
tribe via e-mail correspondence 10 days prior to any grading or construction activities. If the
tribe chooses not to send a monitor or does not respond within the 10 days, work shall
continue without the monitor.
11. ARCHEOLOGICAL AND CULTURAL MONITORING. A qualified archaeologist and a Native
American monitor, registered with the Native American Heritage Commission for the City of
Palo Alto and that is traditionally and culturally affiliated with the geographic area as
described in Public Resources Code Section 21080.3, shall be present during earthmoving
activities including, trenching, initial or full grading, scraping or blading, lifting of
foundation, boring, drilling, or major landscaping. The qualified archaeologist and Native
American monitor shall have the authority to halt construction activities within 50 feet of a
discovery in the event any cultural materials are encountered during ground-disturbing
construction activities. The qualified archeologist and Native American monitor shall keep a
daily monitoring log on days that monitoring occurs documenting construction activities
that were monitored, location of the monitoring, and any cultural materials identified.
These daily monitoring logs shall be made available to the City upon request.
12. ARCHEOLOGICAL AND CULTURAL TREATMENT PLAN. In the event any significant cultural
materials are encountered during construction, construction within a radius of 50 feet of
the find would be halted, the Director of Planning shall be notified, and the on-site qualified
archaeologist, in collaboration with the Native American Monitor, shall examine the find
and make appropriate recommendations regarding the significance of the find and the
appropriate treatment of the resource.
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The qualified archeologist in collaboration with a Native American monitor, registered with
the Native American Heritage Commission for the City of Palo Alto and that is traditionally
and culturally affiliated with the geographic area as described in Public Resources Code
Section 21080.3, shall prepare and implement a treatment plan that reflects permit-level
detail pertaining to depths and locations of excavation activities. The treatment plan shall
contain, at a minimum:
a. Identification of the scope of work and range of subsurface effects (including
location map and development plan), including requirements for preliminary
field investigations.
b. Description of the environmental setting (past and present) and the
historic/prehistoric background of the parcel (potential range of what might be
found).
c. Monitoring schedules and individuals.
d. Development of research questions and goals to be addressed by the
investigation (what is significant vs. what is redundant information).
e. Detailed field strategy to record, recover, or avoid the finds and address research
goals.
f. Analytical methods.
g. Report structure and outline of document contents.
h. Disposition of the artifacts.
i. Security approaches or protocols for finds.
j. Appendices: all site records, correspondence, and consultation with Native
Americans, etc.
The treatment plan shall utilize data recovery methods to reduce impacts on subsurface
resources. The treatment plan must be reviewed and approved by the Director of Planning,
or the Director’s designee prior to implementation of the plan.
13. ARCHEOLOGICAL AND CULTURAL EVALUATION. The project applicant shall notify the
Director of Planning, Native American Monitor, and Archeological Monitor, of any finds
during grading or other construction activities. Any historic or prehistoric material identified
in the project area during excavation activities shall be evaluated for eligibility for listing in
the California Register of Historic Resources as determined by the California Office of
Historic Preservation. Data recovery methods may include, but are not limited to, backhoe
trenching, shovel test, hand augering, and hand-excavation. The techniques used for data
recovery shall follow the protocols identified in the approved treatment plan. Data recovery
shall include excavation and exposure of features, field documentation, and recordation. All
documentation and recordation shall be submitted to the Northwest Information Center,
and the Director of Planning.
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14. UNANTICIPATED DISCOVERY OF BURIED ARCHEOLOGICAL AND TRIBAL CULTURAL
RESOURCES. If human remains are found, the State of California Health and Safety Code
Section 7050.5 states that no further disturbance shall occur until the County Coroner has
made a determination of origin and disposition pursuant to Public Resources Code Section
5097.98. In the event of an unanticipated discovery of human remains, the County Coroner
must be notified immediately. If the human remains are determined to be of Native
American origin, the Coroner will notify the Native American Heritage Commission, which
will determine and notify a most likely descendant (MLD). The MLD has 48 hours from being
granted site access to make recommendations for the disposition of the remains. If the MLD
does not make recommendations within 48 hours, the landowner shall reinter the remains
in an area of the property secure from subsequent disturbance.
15. In accordance with Mitigation measure Air 2a of the Comprehensive Plan EIR, these BMPs
shall be implemented during all demolition, grading, and construction activities to reduce
construction-related particulate emissions:
a. Exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and
unpaved access roads) shall be watered two times per day or covered.
b. Haul trucks transporting soil, sand, or other loose material off-site shall be
covered.
c. Visible mud or dirt track-out onto adjacent public roads shall be removed using
wet power vacuum street sweepers at least once per day. The use of dry power
sweeping is prohibited.
d. Vehicle speeds on unpaved roads shall be limited to 15 miles per hour.
e. Roadways, driveways, and sidewalks to be paved shall be completed as soon as
possible. Building pads shall be laid as soon as possible after grading unless
seeding or soil binders are used.
f. Idling times shall be minimized either by shutting equipment off when not in use
or reducing the maximum idling time to five minutes (as required by the
California airborne toxics control measure Chapter13, Section 2485 of California
Code of Regulations [CCR]). Clear signage explaining this rule shall be provided
for construction workers at all access points.
g. Construction equipment shall be maintained and properly tuned in accordance
with the manufacturer’s specifications. Equipment shall be checked by a
certified mechanic and determined to be running in proper condition prior to
operation.
h. A publicly visible sign shall be posted with the telephone number and name of an
individual working for the construction contractor who can be contacted
regarding dust complaints. This person shall respond and take corrective action
within 48 hours. The BAAQMD’s phone number shall also be visible to ensure
compliance with applicable regulations.
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16. NOISE MITIGATION IN CONFORMANCE WITH COMPREHNSIVE PLAN POLICY N6.11.1 AND
MITIGATION MEASURE NOISE-8 IN THE COMPREHENSIVE PLAN EIR. Noise control measures
would include, but not be limited to, the following BMPs that would further decrease the
project’s noise impacts during construction:
The contractor shall use “new technology” power construction equipment with
state-of-the art noise shielding and muffling devices. All internal combustion engines
used on the project site shall be equipped with adequate mufflers and shall be in
good mechanical condition to minimize noise created by faulty or poorly maintained
engines or other components.
The unnecessary idling of internal combustion engines shall be prohibited.
Staging areas and stationary noise-generating equipment shall be located as far as
possible from noise-sensitive receptors such as residential uses (a minimum of 200
feet)
The surrounding neighborhood shall be notified early and frequently of the
construction activities.
A “noise disturbance coordinator” shall be designated to respond to any local
complaints about construction noise. The disturbance coordinator would determine
the cause of the noise complaints (e.g., beginning work too early, bad muffler, etc.)
and institute reasonable measures warranted to correct the problem. A telephone
number for the disturbance coordinator would be conspicuously posted at the
construction site.
Utilize ‘quiet’ models of air compressors and other stationary noise sources where
technology exists.
Equip all internal combustion engine-driven equipment with mufflers, which are in
good condition and appropriate for the equipment.
Construct temporary noise barriers, where feasible, to screen stationary noise-
generating equipment when located within 200 feet of adjoining sensitive land uses.
Temporary noise barrier fences would provide a 5dBA noise reduction if the noise
barrier interrupts the line of- sight between the noise source and receptor and if the
barrier is constructed in a manner that eliminates any cracks or gaps.
If stationary noise-generating equipment must be located near receptors, adequate
muffling (with enclosures where feasible and appropriate) shall be used. Any
enclosure openings or venting shall face away from sensitive receptors.
Ensure that generators, compressors, and pumps are housed in acoustical
enclosures.
Locate cranes as far from adjoining noise-sensitive receptors as possible.
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During final grading, substitute graders for bulldozers, where feasible. Wheeled
heavy equipment are quieter than track equipment and should be used where
feasible.
Substitute nail guns for manual hammering, where feasible.
Substitute electrically powered tools for noisier pneumatic tools, where feasible.
Prior to building permit issuance the contractor shall prepare a detailed construction
plan identifying the schedule for major noise-generating construction activities. The
construction plan shall identify a procedure for coordination with adjacent
residential land uses so that construction activities can be scheduled to minimize
noise disturbance.
17. NOISE MITIGATION IN CONFORMANCE WITH COMPREHNSIVE POLICY N6.11.1 AND
MITIGATION MEASURE NOISE-5a IN THE COMPREHENSIVE PLAN EIR. The project proponent
shall implement a construction vibration monitoring plan to document conditions prior to,
during, and after vibration generating construction activities for the adjacent residential
uses. All plan tasks shall be undertaken under the direction of a licensed Professional
Structural Engineer in the State of California and be in accordance with industry-accepted
standard methods. The construction vibration monitoring plan shall be submitted to the
City prior to issuance of a Grading or Building Permit and shall include, but not be limited to,
the following measures:
The report shall include a description of measurement methods, equipment used,
calibration certificates, and graphics as required to clearly identify vibration-
monitoring locations.
A list of all heavy construction equipment to be used for this project and the
anticipated time duration of using the equipment that is known to produce high
vibration levels (clam shovel drops, vibratory rollers, hoe rams, large bulldozers,
caisson drillings, loaded trucks, jackhammers, etc.) shall be submitted to the Director
of Planning and Development Services or Director’s designee of the Department of
Planning & Development by the contractor. This list shall be used to identify
equipment and activities that could exceed the 0.3 PPV threshold at the adjacent
residential uses based on the planned equipment, location, and duration of use.
Where project construction activities may be anticipated to exceed the threshold,
the applicant shall provide a plan to show how levels would be reduced by phasing
activities that are known to cause excessive vibration, utilizing alternative
equipment, and/or reducing the time period that the equipment is being used.
Where possible, use of the heavy vibration-generating construction equipment shall
be prohibited within 20 feet of the adjacent residential uses.
o Smaller equipment (less than 18,000 pounds) must be used near the
property lines adjacent to the existing residential uses to minimize vibration
levels to 0.3 in/sec PPV or less. For example, a smaller vibratory roller similar
to a Caterpillar model CP433E vibratory compactor could be used when
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compacting materials within 20 feet of the adjacent residential buildings. The
smaller equipment intended to implement this requirement shall be
individually identified among the list of equipment required under the above
condition as the subset of equipment allowed for use at the property lines.
o Avoid using vibratory rollers and clam shovel drops within 20 feet of the
adjacent residential uses.
o Select demolition methods that do not involve large impact tools such as
hoe-rams within 20 feet of the eastern property line. Portable jackhammers,
saws, or grinders shall be used to minimize impacts to the ground.
o Avoid dropping heavy equipment and use alternative methods for breaking
up existing pavement, such as a pavement grinder, instead of dropping heavy
objects, within 20 feet of the adjacent residential uses.
• Develop a vibration monitoring and construction contingency plan to identify
structures where monitoring would be conducted, set up a vibration monitoring
schedule, define structure-specific vibration limits, and address the need to conduct
photo, elevation, and crack surveys to document before and after construction
conditions. Construction contingencies shall be identified for when vibration levels
approach the limits of 0.3 in/sec PPV at the adjacent residential buildings.
• At a minimum, vibration monitoring shall be conducted during demolition and
excavation activities.
• Designate a person responsible for registering and investigating claims of excessive
vibration. The contact information of such person shall be clearly posted on the
construction site.
Conduct a post-construction survey on structures where either monitoring has
indicated high vibration levels or complaints of damage has been made. Make
appropriate repairs or compensation where damage has occurred as a result of
construction activities.
18. OPEN AIR LOUDSPEAKERS (AMPLIFIED MUSIC). In accordance with PAMC Section 9.12, no
amplified music shall be used for producing sound in or upon any open area, to which the
public has access, between the hours of 11:00pm and one hour after sunrise. In addition, all
rooftop gardens/decks shall comply with the provisions of PAMC 18.42.230.
19. NOISE THRESHOLDS ON RESIDENTIAL PROPERTY. NOISE THRESHOLDS ON RESIDENTIAL
PROPERTY. In accordance with PAMC Section 9.10.030, No person shall produce, suffer or
allow to be produced by any machine, animal or device, or any combination of same, on
residential property, a noise level more than six dB above the local ambient at any point
outside of the property plane. At building permit, provide the proposed HVAC
specifications. If the proposed decibel level of the HVAC exceeds the decibel level of the
HVAC evaluated in the CEQA analysis, a noise analysis of the proposed equipment’s
consistency with the municipal code shall be required.
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20. NOISE REPORT PRIOR TO INSPECTION. Where the acoustical analysis projected noise levels
at or within 5 dB less than the Noise Ordinance limits, the applicant shall demonstrate the
installed equipment complies with the anticipated noise levels and the Noise Ordinance
prior to final Planning inspection approval.
21. SIGN APPROVAL NEEDED. No signs are approved at this time. All signs shall conform to the
requirements of Title 16.20 of the Palo Alto Municipal Code (Sign Code) and shall be subject to
approval by the Director of Planning.
22. UNDERGROUND STORAGE TANK. Prior to issuance of a building permit, the Applicant shall
provide documentation, to the satisfaction of the City and applicable Cleanup Oversight
Agency, demonstrating that the site is suitable for residential use with respect to potential
contamination from the former underground storage tanks.
If required, additional investigation or remediation shall be completed in accordance with
applicable state regulations, including the State Water Board’s Low-Threat UST Case Closure
Policy. Written clearance or a determination of no further action shall be provided prior to
building permit issuance.
23. TRASH ROOM. The trash room shall be used solely for the temporary storage of refuse and
recycling that is disposed on a regular basis and shall be closed and locked during non-
business hours.
24. UTILITY LOCATIONS. In no case shall utilities be placed in a location that requires equipment
and/or bollards to encroach into a required parking space. In no case shall a pipeline or
water and wastewater services/laterals/meters be placed within 10 feet of a proposed tree
and/or tree designated to remain, or within 5 feet where root barrier protection is installed,
unless otherwise approved by urban forestry and waste-gas-water.
25. ESTIMATED IMPACT FEE. Development Impact Fees, currently estimated in the amount of
$17,698,233.70 shall be paid in accordance with PAMC Chapter 16.64. The final
Development Impact Fees shall be calculated before they are due, and payment may be
deferred to the date the development is approved for occupancy as set forth in PAMC
Section 16.64.030 and as permitted by SB 937.
26. IMPACT FEE 90-DAY PROTEST PERIOD. California Government Code Section 66020 provides
that a project applicant who desires to protest the fees, dedications, reservations, or other
exactions imposed on a development project must initiate the protest at the time the
development project is approved or conditionally approved or within ninety (90) days after
the date that fees, dedications, reservations or exactions are imposed on the
Project. Additionally, procedural requirements for protesting these development fees,
dedications, reservations and exactions are set forth in Government Code Section 66020. IF
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YOU FAIL TO INITIATE A PROTEST WITHIN THE 90-DAY PERIOD OR FOLLOW THE PROTEST
PROCEDURES DESCRIBED IN GOVERNMENT CODE SECTION 66020, YOU WILL BE BARRED
FROM CHALLENGING THE VALIDITY OR REASONABLENESS OF THE FEES, DEDICATIONS,
RESERVATIONS, AND EXACTIONS. If these requirements constitute fees, taxes,
assessments, dedications, reservations, or other exactions as specified in Government Code
Sections 66020(a) or 66021, this is to provide notification that, as of the date of this notice,
the 90-day period has begun in which you may protest these requirements. This matter is
subject to the California Code of Civil Procedures (CCP) Section 1094.5; the time by which
judicial review must be sought is governed by CCP Section 1094.6.
27. INDEMNITY. To the extent permitted by law, the Applicant shall indemnify and hold
harmless the City, its City Council, its officers, employees and agents (the “indemnified
parties”) from and against any claim, action, or proceeding brought by a third party against
the indemnified parties and the applicant to attack, set aside or void, any permit or
approval authorized hereby for the Project, including (without limitation) reimbursing the
City for its actual attorneys’ fees and costs incurred in defense of the litigation. The City
may, in its sole discretion, elect to defend any such action with attorneys of its own choice.
28. FINAL INSPECTION. A Planning Division Final inspection will be required to determine
substantial compliance with the approved plans prior to the scheduling of a Building Division
final. Any revisions during the building process must be approved by Planning. Contact your
Project Planner, Steven Switzer at Steven.Switzer@PaloAlto.gov to schedule this inspection.
Public Art
29. The project triggers the Public Art in Private Development ordinance, requiring that 1% of the
estimated cost of construction be spent either on art on-site, or the payment of the
equivalent funds to the Public Art Fund in-lieu of commissioning artwork on site. The
applicant has not submitted a public art application at this time. Prior to issuance of a building
permit, the applicant shall pay the required in-lieu contribution to the Public Art Fund or,
prior to applying for a building permit, shall file a minor architectural review application to
evaluate proposed public art, which shall be reviewed and approved by the public art
commission. The Public Art Program team will need to verify the Construction Valuation with
an outside consultant. Contact the Public Art Program at the time you apply for Building
permit to begin this verification process. All information and application materials may be
found at paloalto.gov/public art under the Policies and Documents tab. In-lieu fees may be
paid at occupancy in accordance with the requirements under PAMC 16.64.030 and as
permitted by SB 937.
Building Division
30. A complete construction set shall be submitted to the building department for review. A
complete construction shall include, but is not limited to: architectural drawings, structural
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drawings and calculations, mechanical plans, electrical plans, plumbing plans, and Title 24
energy analysis.
31. All sheets shall be stamped and signed by the responsible designer.
32. Refer to this website below for additional building permit submittal requirements. Contact
the building department for any questions.
https://www.paloalto.gov/files/assets/public/v/3/development-services/building-
division/checklists/simplified/c1-new-comm-shell-checklist-07062023.pdf
Transportation
33. Prior to issuance of a building permit, the applicant shall obtain a transportation analysis
(TA) consistent with the City's Local Transportation Impact Analysis Policy and prepared by a
consultant reasonably acceptable to the City. The applicant shall implement any mediation
measures recommended in the TA that would not render the project infeasible. Potential
mediation measures could include but not limited to; flex posts, bike boxes, bike sharrows,
and/or speed bumps. At a minimum, the TA shall:
a. Evaluate project ingress and egress operations, including driveway functionality
and queuing;
b. Analyze intersection operations and impacts at the Matadero Avenue / El
Camino Real and Kendall Avenue / El Camino Real intersections, considering the
existing “No Right Turn on Red” restrictions;
c. Evaluate potential impacts to the suggested school route along Matadero
Avenue and Kendall Avenue with respect to multimodal access; and
d. Identify and recommend improvements as necessary, subject to City approval.
34. OFF SITE IMPROVEMENTS: Off-site improvement plans shall be submitted to the Office
of Transportation for review and approval. These improvements shall incorporate all
recommendations identified in the transportation analysis prepared for the project. Off-
site improvements include, but are not limited to, design modifications that support on
site circulation and prevent queuing or other operational deficiencies within the public
right of way. Any proposed modifications to the public right of way shall be evaluated to
ensure they can be safely accommodated given existing lane geometry.
35. TRANSPORTATION DEMAND MANAGEMENT (TDM): The applicant shall prepare and
submit a final TDM Plan consistent with the Comprehensive Plan policies for the El
Camino Real corridor and that demonstrates a minimum 30 percent reduction in project
generated vehicle trips. The plan shall identify parking and trip reduction measures,
include trip targets and a monitoring and enforcement mechanism, and designate the
responsible entity for implementation.
All approved TDM measures shall be maintained for the life of the project. Monitoring
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reports shall be submitted two years after occupancy and annually thereafter. If
performance targets are not met, the applicant shall implement modifications as
required by the Director. Failure to correct deficiencies may result in administrative
penalties or other enforcement actions consistent with the Municipal Code.
36. BICYCLE PARKING: In accordance with California Green Building Standards Code
(CALGreen), the project shall provide one on-site short term bicycle parking space per
10,000 square feet. Short term bicycle parking spaces shall be located within 200 feet of
building entrances and readily visible to passers-by.
37. LOADING ZONES: No project dedicated loading space shall be located within the public
right of way. The project shall maintain at minimum one, on-site loading space.
38. CONSISTENCY WITH CALTRANS SR-82 IMPROVEMENTS: All off site improvements shall
be consistent with the recently completed Caltrans SR 82 (El Camino Real)
improvements, including existing “No Parking” signage along El Camino Real. Any
temporary alterations to bike lane enhancements shall be restored to existing
conditions upon completion of the project.
39. BUS SHELTER COORDINATION: Potential impacts to the existing VTA bus shelter at the
intersection of Matadero Avenue and El Camino Real shall be reviewed and approved
through VTA’s development review process. The applicant shall comply with all
requirements issued by the transit authority.
40. DRIVEWAY SIGHT LINES: Adequate sight distance shall be preserved at all driveways.
a. Landscaping within driveway vision triangles shall be maintained at a maximum
height of three (3) feet.
b. All new and existing trees shall be maintained to provide a minimum vertical
clearance of seven (7) feet above grade to ensure unobstructed visibility.
41. QUEUING: Fast opening gates shall be installed and maintained to ensure that vehicle
queuing does not extend into or impact the public right of way.
42. TRASH REMOVAL AND OPERATIONS: Trash bin staging and collection operations shall
occur entirely on site and shall not encroach into or occur within the public right of way.
Public Works Zero Waste
43. REQUIRED DECONSTRUCTION. In conformance with PAMC 5.24, deconstruction and source
separation are required for all residential and commercial projects where structures (other
than a garage or ADU) are being completely removed, demolition is no longer allowed.
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Deconstruction takes longer than traditional demolition, it is important to plan ahead. For
more information, visit www.cityofpaloalto.org/deconstruction.
44. SALVAGE SURVEY FOR REUSE. A Salvage Survey is required for deconstruction permit
applications. The survey shall be conducted by a City approved reuse vendor. The survey
submittal shall include an itemized list of materials that are salvageable for reuse from the
project. The applicant shall source separate and deliver materials for reuse. Certification is
required indicating that all materials identified in the survey are properly salvaged. Contact
The ReUse People to schedule this FREE survey by phone (888) 588-9490 or e-mail
info@thereusepeople.org. More information can be found at www.TheReusePeople.org.
Please upload a completed copy to the deconstruction permit.
45. SOURCE SEPARATION FOR RECYCLING. The applicant shall source separate deconstruction
materials into specific categories for recycling. Additional staging areas for source separated
materials will need to be considered. All materials shall be delivered to one of the City
approved materials recovery facilities listed in Green Halo, all records shall be uploaded to
www.greenhalosystems.com.
For more information, refer to www. paloalto.gov/deconstruction. Trash enclosure can only
be used to temporarily store refuse (garbage, recycling, and compost) and not for other
storage.
46. On the plans submitted for building permit provide cut-sheets for the color-coded internal
and external containers, related color-coded millwork, and its colored signage in the
building plans. Trash chutes must have colored doors with colored signage that complies
with PAMC 5.20.18 requirements.
47. All indoor and outdoor common spaces are required to comply with the following: As per
Palo Alto Municipal Code 5.20.108 the site is required to have color-coded refuse
containers, related color-coded millwork, and colored signage. The three refuse containers
shall include recycle (blue container), compost (green container), and garbage (black
container). Applicant shall present on the plan submitted for building permit the locations
and quantity of both (any) internal and external refuse containers, it’s millwork, along with
the signage. However, for the copy/ mail area must have either a recycle bin only or all
three refuse receptacles (green compost, blue recycle, and black landfill container). Please
refer to PAMC 5.20.108 and the Internal Container Guide. Examples of appropriate signage
can be found in the Managing Zero Waste at Your Business Guide. Electronic copies of these
signage can be found on the Zero Waste Palo Alto’s website,
https://www.paloalto.gov/Departments/Public-Works/Zero-Waste/What-Goes-
Where/Toolkit#section-2 and hard copies can be requested from the waste hauler,
Greenwaste of Palo Alto, (650) 493-4894.
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Public Works Engineering
48. PUBLIC WORKS APPLICATIONS, FORMS, AND DOCUMENTS: Applicant shall be advised
that most forms, applications, and informational documents related to Public Works
Engineering conditions can be found at the following link:
https://www.cityofpaloalto.org/Departments/Public-Works/Engineering-
Services/Forms-and-Permits
49. OVERVIEW AND GUIDELINES FOR THE REVIEW OF SUBDIVISION PROJECTS: Developer
shall familiarize themselves with the guidelines described in the November 2007
revision of the document titled “Overview and Guidelines for the Review of Subdivision
Projects”. Particularly Section II (items 5 through 12) and Section V (items A through C).
https://www.paloalto.gov/files/assets/public/planning-amp-development-services/file-
migration/current-planning/forms-and-guidelines/overview-and-guidelines-for-the-
review-of-subdivision-projects.pdf
50. PARCEL MAP/FINAL MAP: Approval of this application is subject to, and contingent upon
the approval of a tentative map and recordation of a Final Map, as detailed in Section 8.
51. STREETWORK PERMIT: The applicant shall obtain a Streetwork Permit from the
Department of Public Works for all public improvements.
52. SPECIAL STREET LIGHT: This project is located within an area designated to have special
streetlights as shown in the Special Street Light Style Placement Guide. Any new or
replaced streetlights shall be installed to the standards adopted by the Public Works
Department and Utility Department.
https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development-
services/current-planning/pw-style-placement-guide-2020.pdf
53. UPGRADE OF EXISTING PUBLIC IMPROVEMENTS: As part of the plan review for
improvements within the public right-of-way, any existing improvements to be re-used
by the project, which are not to current City standards and are not specifically in these
project conditions (such as streetlights, utility covers and lids, etc.), shall be upgraded to
current City standards as required by the Director of Public Works and the Director of
Utilities.
54. MODIFICATIONS TO EXISTING PUBLIC UTILITIES: The Developer is responsible for any
changes or modifications to existing utilities, streets, and public infrastructure within or
adjacent to the project site that are attributable to the development. This includes, but
is not limited to, the relocation of utility facilities, conduits, or vaults required due to
grade changes in the sidewalk area resulting from the development. The Developer’s
financial responsibility for utility upgrades exceeding the impacts of the development
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shall be limited to Developer’s fair share contribution, as reasonably determined by the
Utilities and/or Public Works Department.
55. DAMAGE TO EXISTING PUBLIC IMPROVEMENTS: The Developer is responsible for
repairing any damage to existing public improvements fronting or adjacent to the
project site caused by construction, to the satisfaction of the Public Works Department.
56. EXISTING UTILITY ABANDONMENT AND/OR RELOCATION: The Developer is responsible
for researching all existing utility lines to ensure there are no conflicts with the project.
Any existing utility lines (public or private) or their appurtenances that conflict with the
project or do not serve it must be capped, abandoned, removed, relocated, or disposed
of to the satisfaction of the City.
57. RE-USE OF EXISTING STORM DRAINS: The re-use of existing City storm drain service lines
and appurtenances is subject to City review and approval. The Developer’s contractor
shall expose the existing storm drain facilities during construction for City inspection or
provide video documentation of their condition. Any deficient facilities, as determined
by Public Works, must be replaced by the Developer. The Developer’s financial
responsibility for storm drain facility upgrades exceeding the impacts of the
development shall be limited to Developer’s fair share contribution, as reasonably
determined by the Public Works Department.
58. STORM DRAIN TRIBUTARY PATTERN: This project must follow the existing storm drain
tributary pattern. Any deviations require additional analysis and approval by Public
Works during plan review. The project shall not negatively impact the drainage pattern
for adjacent properties.
59. GRADING AND EXCAVATION PERMIT: A Grading Permit is required per PAMC Chapter
16.28. The permit application and all applicable documents (see Section H of
application) shall be submitted to Public Works Engineering. Add the following note:
“THIS GRADING PERMIT WILL ONLY AUTHORIZE GENERAL GRADING AND INSTALLATION
OF THE STORM DRAIN SYSTEM. OTHER BUILDING AND UTILITY IMPROVEMENTS ARE
SHOWN FOR REFERENCE INFORMATION ONLY AND ARE SUBJECT TO SEPARATE
BUILDING PERMIT APPROVAL.”
60. ROUGH GRADING: provide a Rough Grading Plan for the work proposed as part of the
Grading and Excavation Permit application. The Rough Grading Plans shall including the
following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over
excavation, stockpile area of material, overall earthwork volumes (cut and fill),
temporary shoring for any existing facilities, ramps for access, crane locations (if any),
tree protection measures, etc.
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61. CIVIL ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the
final completion of the work, applicant shall provide an as-graded grading plan prepared
by the civil engineer that includes original ground surface elevations, as-graded ground
surface elevations, lot drainage patterns and locations and elevations of all surface and
subsurface drainage facilities. The civil engineer shall certify that the work was done in
accordance with the final approved grading plan.
62. DIRECT CONNECTIONS TO STORM DRAIN SYSTEM: If the project proposes to replace
and/or add connections to the City maintained storm drain system, then the applicant
may be responsible for improvements to the system. These improvements may include,
but not limited to, upsizing the storm drain facility, replacing or adding City standard
catch basins, pipes and manholes. THIS MAY INCLUDE REPLACING BRICK AND MORTAR
MANHOLES. The extent of required improvements will be at the public works staff
discretion and shall be consistent with Storm Drain Master Plan and Public Works
Construction Standards. Any work on the city's storm drain systems requires permits
and inspection by Public Works inspectors. The Developer’s financial responsibility for
storm drain facility upgrades exceeding the impacts of the development shall be limited
to Developer’s fair share contribution, as reasonably determined by the Public Works
Department.
63. CCTV OF STORM DRAIN SYSTEM: Post construction the applicant may be required to
provide CCTV inspection of the City’s storm drain facilities to verify that any lines were
not broken, cracked or damaged during construction. The video shall be high resolution
and done by professional who is familiar with the process and meticulous. A CCTV
inspection video is required for new storm drain connection (s) to verify proper
connections were made into the City’s system and that no construction material was left
behind. Videos of storm drain system may also be required where construction occurred
less than 5-ft from the city’s storm drain system. Videos shall be provided from structure
to structure, such as manhole to manhole. Contractor may want to conduct their own
inspection in advance of construction to verify the existing pipe integrity. If existing
damages are located, they shall be reported to Public Works inspectors prior to the start
of construction. If not reported, the contractor may be responsible to restore the pipe
segment as determined by Public Works prior to final.
64. GEOTECHNICAL ENGINEER STATEMENT: The grading plans shall include the following
statement signed and sealed by the Geotechnical Engineer of Record: “THIS PLAN HAS
BEEN REVIEWED AND FOUND TO BE IN GENERAL CONFORMANCE WITH THE INTENT
AND PURPOSE OF THE GEOTECHNICAL REPORT”.
65. SWPPP: This proposed development will disturb more than one acre of land.
Accordingly, the applicant shall apply for coverage under the State Water Resources
Control Board’s (SWRCB) NPDES general permit for storm water discharge associated
with construction activity. A Notice of Intent (NOI) shall be filed for this project with the
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SWRCB in order to obtain coverage under the permit. The General Permit requires the
applicant to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP).
The applicant is required to submit two copies of the NOI and the draft SWPPP to the
Public Works Department for review and approval prior to issuance of the building
permit. The SWPPP should include both permanent, post-development project design
features and temporary measures employed during construction.
66. ENCROACHMENT PERMIT: Prior to any work in the public right-of-way, the applicant
shall obtain an encroachment permit from the Public Works Department for any work
that encroaches onto the City right-of-way.
67. LOGISTICS PLAN: A construction logistics plan shall be provided addressing all impacts
to the public including, at a minimum: work hours, noticing of affected businesses, bus
stop relocations, construction signage, dust control, noise control, storm water pollution
prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane
lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck
routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance,
Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may
require an encroachment permit.
68. STORMWATER POLLUTION PREVENTION: All improvement plan sets shall include the
“Pollution Prevention – It’s Part of the Plan” sheet.
69. C.3 THIRD-PARTY CERTIFICATION: Applicant shall provide certification from a qualified
third-party reviewer that the proposed permanent storm water pollution prevention
measures comply with the requirements of Provision C.3 and Palo Alto Municipal Code
Chapter 16.11. Submit the following:
a. Provide a stamped and signed C.3 data form (April 2024 version) from
SCVURPPP. https://scvurppp.org/2024/09/19/provision-c-3-data-form-2024/
b. Final stamped and signed letter confirming which documents were reviewed and
that the project complies with Provision C.3 and PAMC 16.11.
70. C.3 STORMWATER AGREEMENT: The applicant shall enter into a Stormwater
Maintenance Agreement with the City to guarantee the ongoing maintenance of the
permanent storm water pollution prevention measures. The City will inspect the
treatment measures yearly and charge an inspection fee. The agreement shall be
executed by the applicant team prior to building permit final.
71. C.3 FINAL THIRD PARTY CERTIFICATION PRIOR TO OCCUPANCY: Within 45 days of the
installation of the required storm water treatment measures and prior to the issuance
of an occupancy permit for the building, the third-party reviewer shall submit to the City
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a certification verifying that all the permanent storm water pollution prevention
measures were installed in accordance with the approved plans.
72. PAVEMENT RESTORATION: The applicant shall restore the pavement along the entire
project frontage, curb-to-curb, by performing a 3.5” grind and overlay. The exact
restoration limits will be determined once the resulting road condition is known
following completion of heavy construction activities and utility lateral installations, at
minimum the extent will be the project frontage on Matadero and Kendall Avenues. The
extent of restoration required on El Camino Real shall be determined by the Public
Works Department following completion of heavy construction activities and utility
lateral installations.
73. EXISTING EASEMENTS: Provide documentation showing approval from the entities
affected by the onsite easements to verify that the work within said easements is
permitted.
74. OUTSIDE AGENCY APPROVAL: A portion of the proposed work is within Caltrans right-of-
way. Evidence of permit approvals shall be submitted prior to issuance of City permits.
75. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (STORM DRAIN LOGO): The applicant is
required to paint “No Dumping/Flows to Matadero Creek” in blue on a white
background adjacent to all onsite storm drain inlets. The name of the creek to which
the proposed development drains can be obtained from Public Works Engineering.
Stencils of the logo are available from the Public Works Environmental Compliance
Division, which may be contacted at (650) 329-2598. Include the instruction to paint the
logos on the construction grading and drainage plan.
76. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (RECORD DRAWINGS): At the conclusion
of the project applicant shall provide digital as-built/record drawings of all
improvements constructed in the public right-of-way or easements in which the City
owns an interest.
77. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (INDEFINITE ENCROACHMENT PERMIT):
An approved indefinite encroachment permit will be required for any private
infrastructure constructed in the public right-of-way, easement or on property in which
the City holds an interest, but that was not authorized by a building permit.
Urban Forestry
78. Post building permit issuance all protected trees are subject to a 14-day public notice
prior to their removal.
79. URBAN FORESTRY GENERAL: The following general tree preservation measures apply to
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all trees to be retained: No storage of material, topsoil, vehicles or equipment shall be
permitted within the Tree Protection Zone (TPZ). The ground under and around the tree
canopy area shall not be altered. No waste material or construction byproducts are
allowed within the TPZ. Trees to be retained shall be irrigated, aerated, and maintained
as necessary to ensure survival.
80. TREE DAMAGE: Tree Damage, Injury Mitigation, and Inspections apply to the Contractor.
Reporting, injury mitigation measures, and arborist inspection schedule may apply
pursuant to TLTM, Section 5.03.6. Contractor shall be responsible for the repair or
replacement of any publicly owned or protected trees that are damaged during the
course of construction, pursuant to Title 8 of the Palo Alto Municipal Code, and City of
Palo Alto Tree and Landscape Technical Manual, Section 3.02.
81. TPZ EXCAVATION RESTRICTIONS APPLY - TLTM, Sec. 3.03.6 - B5,6: Any approved grading,
digging, potholing, or trenching within the TPZ of a protected tree shall be performed
using ‘air-spade’ method as a preference, with manual hand shovel as a backup. (TPZ=
10x the tree diameter at 54" above grade) For utility trenching, including sewer line,
roots exposed with a diameter of 2 inches and greater shall remain intact and not be
damaged. If directional boring method is used to tunnel beneath roots, then CPA
Standard Detail #504 shall be printed on the final plans and the buffer distances in TLTM
Table 3-4,Trenching and Tunneling Distance, shall be implemented by Contractor.
Contractor must notify the Urban Forestry Section at (650) 496-5953 in advance of
conducting any approved excavation within 10-feet of any street trees (or for any
protected tree on EVSE projects). Urban Forestry may choose to monitor or review the
work for compliance with the City’s Tree Protection Zone (TPZ) excavation standards.
82. TREE PROTECTION COMPLIANCE: The owner and contractor shall implement all
protection and inspection schedule measures, design recommendations, and
construction scheduling as stated in the Tree Preservation Report and/or T-1 Sheet Set
and is subject to code compliance action pursuant to PAMC 8.10.080. The required
protective fencing shall remain in place until the final landscaping or Urban Forestry
inspection of the project is completed.
83. NO NET LOSS OF CANOPY: In order to comply with the City’s no net loss of canopy policy
(PAMC 8.10.055; Urban Forest Master Plan Goals 6.A, 6.B, & 6.C; Comprehensive Plan,
Natural Environment Chapter Goal N-2) all trees 4 inches DBH and larger are subject to
replacement to avoid a loss of canopy at the neighborhood level. Replacement ratios
are determined by table 3-1 in the Tree and Landscape Technical Manual, Section 3.02.
New landscape tree plantings (24 inch box or larger) count towards the replacement
total. Screening trees may also count toward the total depending on size and species
selected. If unable to plant the required number of trees on site (our preferred solution)
there is the option of paying in-lieu fees per each 24 inch box tree into the forestry fund.
[Note: A replacement at ratio of 1:1 for trees listed as exempt species under PAMC
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8.10.020 is recommended. Exempt trees may require full replacement on parcels zoned
other than R1, RE, R-2, or RMD].
84. PLAN CHANGES: Revisions and/or changes to plans before or during construction shall
be reviewed and responded to by the (a) project site arborist, or (b) landscape architect
with written letter of acceptance before submitting the revision to Planning and
Development Services Department for review by Planning, Public Works, or Urban
Forestry.
85. PLAN SET REQUIREMENTS: The final Plans submitted for a building permit shall include
the location, DBH, canopy drip-line, and TPZ of all trees 4 inches DBH or greater as well
as the following information and notes on relevant plan sheets:
a. T-1 SHEET SET, The building permit plan set will include the City’s full-sized, T-1
Sheet Set (Tree Protection-it's Part of the Plan!), available on the Development
Center website. A certified arborist shall complete and sign the Tree Disclosure
Statement.
b. TREE PRESERVATION REPORT (TPR), if indicated by Tree Disclosure Statement, All
sheets of the Applicant’s TPR approved by the City for full implementation by
Contractor, shall be printed on numbered T-1 Sheets (T-3, T-4, etc.) and added to
the sheet index.
c. TREE PROTECTION FENCING, The Plan Set (esp. site, demolition, grading &
drainage, foundation, irrigation, tree disposition, utility sheets, etc.) must
delineate/show the correct configuration of Type I, Type II or Type III fencing
around each Protected Tree, using a bold dashed line enclosing the Tree
Protection Zone (CPA Standard Detail #605).
Fire
86. Fire sprinkler density of parking garage with EVCE shall be Extra Hazard-II. Install smoke
removal sys in parking garage.
87. Overhead utilities on both Kendall Ave and Matadero Ave shall be placed underground
along exterior walls of this project.
Watershed Protection
The following comments are provided as a courtesy and these conditions of approval must be
complied with before receiving a Demolition Permit for this project:
88. NOTICE OF REGULATION OF PCB MATERIAL – EFFECTIVE JULY 1st, 2019: Please be
advised that requirements regarding stormwater control during building demolition for
polychlorinated biphenyls (PCBs) became effective starting July 1st, 2019, in accordance
with the San Francisco Bay Region Municipal Regional Stormwater NPDES Permit (MRP),
Order No. R2-2015-0049. MRP Provision C.12.f. requires that San Francisco Bay Area
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municipalities develop a program to ensure that PCBs from building materials (e.g.
caulk, paint, mastic) do not enter the storm drain system during building demolition.
Palo Alto City Council adopted the PCBs regulation in May 2019. For specific questions
about your project, please email CleanBay@cityofpaloalto.org, call 650-329-2122 or visit
http://www.cityofpaloalto.org/pcbdemoprogram.
89. If the project is submitting a demolition permit application on or after July 1st, 2019, the
applicant shall complete and submit the “PCBs Applicant Package,” including any
required sampling reports (per the Applicant Package instructions), with the demolition
permit application. The PCBs Application Package and other resources are outlined at
http://www.cityofpaloalto.org/pcbdemoprogram. The Applicant Package will outline
PCBs sampling and reporting requirements that must be met if the project meets ALL of
the following conditions:
a. The project is a commercial, public, institutional, or industrial structure
constructed or remodeled between January 1, 1950 and December 31, 1980.
Single-family and two-family homes are exempt regardless of age.
b. The framing of the building contains material other than wood. Wood-frame
structures are exempt.
c. The proposed demolition is a complete demolition of the building. Partial
demolitions do not apply to the requirements.
90. If the project triggers polychlorinated biphenyls (PCBs) sampling as identified on the
“PCBs Applicant Package,” then the project shall conduct representative sampling of
PCBs concentration in accordance with the “Protocol for Evaluating Priority PCBs-
Containing Materials before Building Demolition (2018).”
If the representative sample results or records DO NOT indicate PCB
concentrations ≥50 ppm in one or more “priority materials,” then the screening
assessment is complete. Applicant submits screening form and the supporting
sampling documentation with the demolition permit application. No additional
action is required.
If the representative sample results or records DO indicate PCBs concentrations
≥50 ppm in one or more “priority materials,” then the screening assessment is
complete, but the Applicant MUST also contact applicable State and Federal
Agencies to meet further requirements. Applicant submits screening form and
the supporting sampling documentation with the demolition permit application,
and also must contact the State and Federal Agencies as indicated on Page 3 of
the “PCBs Screening Assessment Form.”
IMPORTANT: ADVANCED APPROVAL FROM THE UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY (USEPA) OR OTHER STATE AGENCIES MAY BE REQUIRED PRIOR TO
BUILDING DEMOLITION. IT IS RECOMMENEDED THAT APPLICANTS BEGIN THE PCBs
ASSESSMENT WELL IN ADVANCE OF APPLYING FOR DEMOLITION PERMIT AS THE
PROCESS CAN TAKE BETWEEN 1-3 MONTHS.
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91. Requirement for oil-water separator in interior parking garage floor drains: If installed,
parking garage floor drains on interior levels shall be connected to an oil-water
separator prior to discharging to the sanitary sewer system. The oil-water separator
shall be cleaned at a frequency of at least once every twelve (12) months or more
frequently if recommended by the manufacturer or required by the Director.
Installation, certification, and maintenance records shall be maintained and made
available for inspection and copying as described in Section 16.09.155 of this Chapter.
Oil-water separators shall have a minimum capacity of 100 gallons (PAMC
16.09.165(a)(8) and 16.09.170(a)(5)).
92. Exemption for requirements below: This requirement can be exempted if no washing is
allowed on-site via rental/lease agreement, any hose bibs are to be fitted with lock-outs
or other connection controls, and signage is posted indicating that car washing is not
allowed (PAMC 16.09.170(a)(6)).
a. Requirement for an oil-water separator for carwash area: A drain shall be
installed to capture all vehicle wash waters and shall be connected to an oil-
water separator prior to discharge to the sanitary sewer system. The oil-water
separator shall be cleaned at a frequency of at least once every
twelve(12)months or more frequently if recommended by the manufacturer or
required by the Director. Oil-water separators shall have a minimum capacity
of100 gallons.
b. Requirement for bermed area around carwash: The area shall be graded or
bermed in such a manner as to prevent the discharge of stormwater to the
sanitary sewer system
93. Discharge drains for pools, spas, and fountains shall not be connected directly to the
storm drain system or to the sanitary sewer system (PAMC 16.09.165(a)(7) and
16.09.170(a)(4)).
Water-Gas-Wastewater Utilities
The following comments are required to be addressed prior to submittal of any future related
permit application such as a Building Permit, Excavation and Grading Permit, Certificate of
Compliance, Street Work Permit, Encroachment Permit, etc. These comments are provided as a
courtesy and are not required to be addressed prior to the Planning entitlement approval:
94. The applicant is to submit flow monitoring data for the sewer connection utility impact
study.
PRIOR TO ISSUANCE OF DEMOLITION PERMIT (if required)
95. The applicant shall submit a request to disconnect utility services and remove meters.
The utilities demo is to be processed within 10 working days after receipt of the request.
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The demolition permit will be issued by the building inspection division after all utility
services and/or meters have been disconnected and removed.
FOR BUILDING PERMIT
96. The Domestic Water meter and service location is to be finalized in the Building Permit.
This includes the Public Utility Easement (P.U.E) for the Water meter. Sizing of meter
and service to be determined in the Building Permit. Water meter is to comply with City
of Palo Alto Utilities Standard Detail WD-04.
97. The Irrigation Meter location is to be finalized in the Building Permit. Service is to be
relocated to connect off the domestic service. Sizing of meter and service to be
determined in the Building Permit.
98. Fire Service location is to be finalized in the Building Permit.
99. Sewer Alignments are to be finalized in the Building Permit.
100. The applicant shall submit a completed water-gas-wastewater service connection
application - load sheet for the City of Palo Alto Utilities. The applicant must provide all
the information requested for utility service demands (water in fixture units/g.p.m., gas
in b.t.u.h, and sewer in fixture units/g.p.d.). The applicant shall provide the existing
(prior) loads, the new loads, and the combined/total loads (the new loads plus any
existing loads to remain).
101. The applicant shall submit improvement plans for utility construction. The plans must
show the size and location of all underground utilities within the development and the
public right of way including meters, backflow preventers, fire service requirements,
sewer mains, sewer cleanouts, sewer lift stations, and any other required utilities. Plans
for new wastewater laterals and mains need to include new wastewater pipe profiles
showing existing potentially conflicting utilities especially storm drain pipes, electric
and communication duct banks. Existing duct banks need to be daylighted by potholing
to the bottom of the duct bank to verify cross section prior to plan approval and
starting lateral installation. Plans for new storm drain mains and laterals need to
include profiles showing existing potential conflicts with sewer, water, and gas.
102. The applicant must show on the site plan the existence of any auxiliary water supply,
(i.e. water well, gray water, recycled water, rain catchment, water storage tank, etc).
103. The applicant shall be responsible for installing and upgrading the existing utility mains
and/or services, laterals as necessary to handle anticipated peak loads. This
responsibility includes all costs associated with the design and construction for the
installation/upgrade of the utility mains and/or services/laterals. The Developer’s
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financial responsibility for utility upgrades exceeding the impacts of the development
shall be limited to Developer’s fair share contribution, as reasonably determined by the
Utilities Department.
104. An approved reduced pressure principle assembly (RPPA backflow preventer device) is
required for all existing and new water connections from Palo Alto Utilities to comply
with requirements of California administrative code, title 17, sections 7583 through
7605 inclusive. The RPPA shall be installed on the owner's property and directly behind
the water meter within 5 feet of the property line. RPPA's for domestic service shall be
lead free. Show the location of the RPPA on the plans.
105. An approved reduced pressure detector assembly (RPDA backflow preventer device,
STD. WD-12A or STD. WD-12B) is required for all existing and new fire water
connections from Palo Alto Utilities to comply with requirements of California
administrative code, title 17, sections 7583 through 7605 inclusive. The RPDA shall be
installed on the owner's property and directly behind the City owned meter, within 5'
(feet) of the property line or City Right of Way.
106. All backflow preventer devices shall be approved by the WGW engineering division.
Inspection by the city inspector is required for the supply pipe between the meter and
the assembly.
107. The applicant shall pay the capacity fees and connection fees associated with new
utility service/s or added demand on existing services. The approved relocation of
services, meters, hydrants, or other facilities will be performed at the cost of the
person/entity requesting the relocation.
108. If a new water service line installation for fire system usage is required. Show the
location of the new water service on the plans. The applicant shall provide to the
engineering department a copy of the plans for fire system including all fire
department's requirements.
109. Each unit or building shall have its own water meter and gas meter shown on the plans.
Each parcel shall have its own water and gas service and sewer lateral connection
shown on the plans.
110. A sewer lateral per lot is required. Show the location of the new sewer lateral on the
plans. A profile of the sewer lateral is required showing any possible conflicts with
storm, electric/communications ductbanks or other utilities.
111. All existing water, and gas. and wastewater services/laterals that will not be reused
shall be abandoned at the main per the latest WGW utilities standards.
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112. Utility vaults, transformers, utility cabinets, concrete bases, or other structures cannot
be placed over existing water, gas, or wastewater mains/services. Maintain 1'
horizontal clear separation from the vault/cabinet/concrete base to existing utilities as
found in the field. If there is a conflict with existing utilities, Cabinets/vaults/bases shall
be relocated from the plan location as needed to meet field conditions. Trees may not
be planted within 10 feet of existing water, gas, and wastewater mains/laterals/water
services/or meters. New water or wastewater services/laterals/meters may not be
installed within 10' of existing trees. Maintain 10' between new trees and new water
and wastewater services/laterals/meters.
SECTION 8. Conditions of Approval Vesting Tentative Map.
Planning
1. PROJECT PLANS. The Final Map submitted for review and approval by the City Council
shall be in substantial conformance with the Vesting Tentative Map titled “VESTING
TENTATIVE MAP – 3606 EL CAMINO REAL (25PLN-00243)”, prepared by Kier+Wright and
submitted February 3, 2026, except as modified to incorporate the conditions of this
approval.
2. FINAL MAP COVER PAGE. At such time as the Final Map is filed, the cover page shall
include the name and title of the Director of Planning and Development Services.
3. DEVELOPMENT IMPACT FEES. The Property Owner or their designee shall pay all
applicable development impact fees associated with the proposed development and
subdivision prior to issuance of the building permit(s) or recordation of the Final Map, as
detailed in the Major Architectural Review Approval. Impact fees may be paid prior to
occupancy in accordance with the requirements under PAMC 16.64.030 and as
permitted by SB 937, with a lien on the property.
4. IMPACT FEE 90-DAY PROTEST PERIOD. California Government Code Section 66020
provides that a project applicant who desires to protest the fees, dedications,
reservations, or other exactions imposed on a development project must initiate the
protest at the time the development project is approved or conditionally approved or
within ninety (90) days after the date that fees, dedications, reservations or exactions
are imposed on the Project. Additionally, procedural requirements for protesting these
development fees, dedications, reservations and exactions are set forth in Government
Code Section 66020. IF YOU FAIL TO INITIATE A PROTEST WITHIN THE 90-DAY PERIOD
OR FOLLOW THE PROTEST PROCEDURES DESCRIBED IN GOVERNMENT CODE SECTION
66020, YOU WILL BE BARRED FROM CHALLENGING THE VALIDITY OR REASONABLENESS
OF THE FEES, DEDICATIONS, RESERVATIONS, AND EXACTIONS. If these requirements
constitute fees, taxes, assessments, dedications, reservations, or other exactions as
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specified in Government Code Sections 66020(a) or 66021, this is to provide notification
that, as of the date of this notice, the 90-day period has begun in which you may protest
these requirements. This matter is subject to the California Code of Civil Procedures
(CCP) Section 1094.5; the time by which judicial review must be sought is governed by
CCP Section 1094.6.
5. INDEMNITY. To the extent permitted by law, the Applicant shall indemnify and hold
harmless the City, its City Council, its officers, employees and agents (the “indemnified
parties”) from and against any claim, action, or proceeding brought by a third party
against the indemnified parties and the applicant to attack, set aside or void, any permit
or approval authorized hereby for the Project, including (without limitation) reimbursing
the City for its actual attorneys’ fees and costs incurred in defense of the litigation. The
City may, in its sole discretion, elect to defend any such action with attorneys of its own
choice.
Public Works Engineering
6. PUBLIC WORKS APPLICATIONS, FORMS, AND DOCUMENTS: Applicant shall be advised
that most forms, applications, and informational documents related to Public Works
Engineering conditions can be found at the following link: https://www.
paloalto.gov/Departments/Public-Works/Engineering-Services/Forms-and-Permits
7. OVERVIEW AND GUIDELINES FOR THE REVIEW OF SUBDIVISION PROJECTS: Developer
shall familiarize themselves with the guidelines described in the November 2007
revision of the document titled “Overview and Guidelines for the Review of Subdivision
Projects”. Particularly Section II (items 5 through 12) and Section V (items A through C).
https://www.paloalto.gov/files/assets/public/planning-amp-development-services/file-
migration/current-planning/forms-and-guidelines/overview-and-guidelines-for-the-
review-of-subdivision-projects.pdf
8. SUBDIVISION IMPROVEMENT AGREEMENT: The applicant shall execute a Subdivision
Improvement Agreement and provide improvement securities (Bonds) for all proposed
public improvements. THE AGREEMENT SHALL BE EXECUTED PRIOR TO MAP
RECORDATION OR ISSUANCE OF ANY PERMITS FOR CONSTRUCTION, ONSITE AND
OFFSITE. ADVISORY -- The applicant shall provide a detailed itemized stamped and
signed engineer's estimate for all off-site public improvements which will be reviewed to
determine the security amount.
9. PARCEL MAP/FINAL MAP: This project is subject to, and contingent upon the approval of
a tentative map and recordation of a Final Map. The submittal, approval and
recordation of the Map shall be in accordance with the provisions of the California
Subdivision Map Act and Palo Alto Municipal Code Title 21 Subdivision requirements. All
existing and proposed property lines, easements, dedications shown on the tentative
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map are subject to City’s technical review and staff approval during the map process
prior to issuance of any construction permits.
10. MAP THIRD-PARTY REVIEW: The City contracts with a third-party surveyor that will
review and provide approval of the map’s technical correctness as the City Surveyor, as
permitted by the Subdivision Map Act. The Public Works Department will forward a
Scope & Fee Letter from the third-party surveyor, and the applicant will be responsible
for payment of the fee’s indicated therein, which is based on the complexity of the map.
11. STREETWORK PERMIT: The applicant shall obtain a Streetwork Permit from the
Department of Public Works for all public improvements.
12. SPECIAL STREET LIGHT: This project is located within an area designated to have special
streetlights as shown in the Special Street Light Style Placement Guide. Any new or
replaced streetlights shall be installed to the standards adopted by the Public Works
Department and Utility Department.
https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development-
services/current-planning/pw-style-placement-guide-2020.pdf
13. UPGRADE OF EXISTING PUBLIC IMPROVEMENTS: As part of the plan review for
improvements within the public right-of-way, any existing improvements to be re-used
by the project, which are not to current City standards and are not specifically in these
project conditions (such as streetlights, utility covers and lids, etc.), shall be upgraded to
current City standards as required by the Director of Public Works and the Director of
Utilities.
14. MODIFICATIONS TO EXISTING PUBLIC UTILITIES: The Developer is responsible for any
changes or modifications to existing utilities, streets, and public infrastructure within or
adjacent to the project site. This includes, but is not limited to, the relocation of utility
facilities, conduits, or vaults required due to grade changes in the sidewalk area
resulting from the development.
15. DAMAGE TO EXISTING PUBLIC IMPROVEMENTS: The Developer is responsible for
repairing any damage to existing public improvements fronting or adjacent to the
project site caused by construction, to the satisfaction of the Public Works Department.
16. EXISTING UTILITY ABANDONMENT AND/OR RELOCATION: The Developer is responsible
for researching all existing utility lines to ensure there are no conflicts with the project.
Any existing utility lines (public or private) or their appurtenances that conflict with the
project or do not serve it must be capped, abandoned, removed, relocated, or disposed
of to the satisfaction of the City.
17. RE-USE OF EXISTING STORM DRAINS: The re-use of existing City storm drain service lines
and appurtenances is subject to City review and approval. The Developer’s contractor
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shall expose the existing storm drain facilities during construction for City inspection or
provide video documentation of their condition. Any deficient facilities, as determined
by Public Works, must be replaced by the Developer.
18. STORM DRAIN TRIBUTARY PATTERN: This project must follow the existing storm drain
tributary pattern. Any deviations require additional analysis and approval by Public
Works during plan review. The project shall not negatively impact the drainage pattern
for adjacent properties.
19. GRADING AND EXCAVATION PERMIT: A Grading Permit is required per PAMC Chapter
16.28. The permit application and all applicable documents (see Section H of
application) shall be submitted to Public Works Engineering. Add the following note:
“THIS GRADING PERMIT WILL ONLY AUTHORIZE GENERAL GRADING AND INSTALLATION
OF THE STORM DRAIN SYSTEM. OTHER BUILDING AND UTILITY IMPROVEMENTS ARE
SHOWN FOR REFERENCE INFORMATION ONLY AND ARE SUBJECT TO SEPARATE
BUILDING PERMIT APPROVAL.”
20. ROUGH GRADING: provide a Rough Grading Plan for the work proposed as part of the
Grading and Excavation Permit application. The Rough Grading Plans shall include the
following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over
excavation, stockpile area of material, overall earthwork volumes (cut and fill),
temporary shoring for any existing facilities, ramps for access, crane locations (if any),
tree protection measures, etc.
21. CIVIL ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the
final completion of the work, applicant shall provide an as-graded grading plan prepared
by the civil engineer that includes original ground surface elevations, as-graded ground
surface elevations, lot drainage patterns and locations and elevations of all surface and
subsurface drainage facilities. The civil engineer shall certify that the work was done in
accordance with the final approved grading plan.
22. DIRECT CONNECTIONS TO STORM DRAIN SYSTEM: If the project proposes to replace
and/or add connections to the City maintained storm drain system, then the applicant
may be responsible for improvements to the system. These improvements may include,
but not limited to, upsizing the storm drain facility, replacing or adding City standard
catch basins, pipes and manholes. THIS MAY INCLUDE REPLACING BRICK AND MORTAR
MANHOLES. The extent of required improvements will be at the public works staff
discretion and shall be consistent with Storm Drain Master Plan and Public Works
Construction Standards. Any work on the city's storm drain systems requires permits
and inspection by Public Works inspectors. The Developer’s financial responsibility for
storm drain facility upgrades exceeding the impacts of the development shall be limited
to Developer’s fair share contribution, as reasonably determined by the Public Works
Department.
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23. CCTV OF STORM DRAIN SYSTEM: Post construction the applicant may be required to
provide CCTV inspection of the City’s storm drain facilities to verify that any lines were
not broken, cracked or damaged during construction. The video shall be high resolution
and done by professional who is familiar with the process and meticulous. A CCTV
inspection video is required for new storm drain connection (s) to verify proper
connections were made into the City’s system and that no construction material was left
behind. Videos of storm drain system may also be required where construction occurred
less than 5-ft from the city’s storm drain system. Videos shall be provided from structure
to structure, such as manhole to manhole. Contractor may want to conduct their own
inspection in advance of construction to verify the existing pipe integrity. If existing
damages are located, they shall be reported to Public Works inspectors prior to the start
of construction. If not reported, the contractor may be responsible to restore the pipe
segment as determined by Public Works prior to final.
24. GEOTECHNICAL ENGINEER STATEMENT: The grading plans shall include the following
statement signed and sealed by the Geotechnical Engineer of Record: “THIS PLAN HAS
BEEN REVIEWED AND FOUND TO BE IN GENERAL CONFORMANCE WITH THE INTENT
AND PURPOSE OF THE GEOTECHNICAL REPORT”.
25. SWPPP: This proposed development will disturb more than one acre of land.
Accordingly, the applicant shall apply for coverage under the State Water Resources
Control Board’s (SWRCB) NPDES general permit for storm water discharge associated
with construction activity. A Notice of Intent (NOI) shall be filed for this project with the
SWRCB in order to obtain coverage under the permit. The General Permit requires the
applicant to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP).
The applicant is required to submit two copies of the NOI and the draft SWPPP to the
Public Works Department for review and approval prior to issuance of the building
permit. The SWPPP should include both permanent, post-development project design
features and temporary measures employed during construction.
26. ENCROACHMENT PERMIT: Prior to any work in the public right-of-way, the applicant
shall obtain an encroachment permit from the Public Works Department for any work
that encroaches onto the City right-of-way.
27. LOGISTICS PLAN: A construction logistics plan shall be provided addressing all impacts
to the public including, at a minimum: work hours, noticing of affected businesses, bus
stop relocations, construction signage, dust control, noise control, storm water pollution
prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane
lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck
routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance,
Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may
require an encroachment permit.
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28. STORMWATER POLLUTION PREVENTION: All improvement plan sets shall include the
“Pollution Prevention – It’s Part of the Plan” sheet.
29. C.3 THIRD-PARTY CERTIFICATION: Applicant shall provide certification from a qualified
third-party reviewer that the proposed permanent storm water pollution prevention
measures comply with the requirements of Provision C.3 and Palo Alto Municipal Code
Chapter 16.11. Submit the following:
a. Provide a stamped and signed C.3 data form (April 2024 version) from
SCVURPPP. https://scvurppp.org/2024/09/19/provision-c-3-data-form-2024/
b. Final stamped and signed letter confirming which documents were reviewed and
that the project complies with Provision C.3 and PAMC 16.11.
30. C.3 STORMWATER AGREEMENT: The applicant shall enter into a Stormwater
Maintenance Agreement with the City to guarantee the ongoing maintenance of the
permanent storm water pollution prevention measures. The City will inspect the
treatment measures yearly and charge an inspection fee. The agreement shall be
executed by the applicant team prior to building permit final.
31. C.3 FINAL THIRD PARTY CERTIFICATION PRIOR TO OCCUPANCY: Within 45 days of the
installation of the required storm water treatment measures and prior to the issuance
of an occupancy permit for the building, the third-party reviewer shall submit to the City
a certification verifying that all the permanent storm water pollution prevention
measures were installed in accordance with the approved plans.
32. PAVEMENT RESTORATION: The applicant shall restore the pavement along the entire
project frontage, curb-to-curb, by performing a 3.5” grind and overlay. The exact
restoration limits will be determined once the resulting road condition is known
following completion of heavy construction activities and utility lateral installations, at
minimum the extent will be the project frontage.
33. EXISTING EASEMENTS: Provide documentation showing approval from the entities
affected by the onsite easements to verify that the work within said easements is
permitted.
34. OUTSIDE AGENCY APPROVAL: A portion of the proposed work is within Caltrans right-of-
way. Be advised that the following storm drain infrastructure is owned by Caltrans and
therefore will require their approval prior to City permit issuance. Items owned by
Caltrans:
a. 15-inch storm main along El Camino,
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b. Catch basins on Matadero/El Camino intersection, and associated proposed
improvements.
35. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (STORM DRAIN LOGO): The applicant is
required to paint “No Dumping/Flows to Matadero Creek” in blue on a white
background adjacent to all onsite storm drain inlets. The name of the creek to which
the proposed development drains can be obtained from Public Works Engineering.
Stencils of the logo are available from the Public Works Environmental Compliance
Division, which may be contacted at (650) 329-2598. Include the instruction to paint the
logos on the construction grading and drainage plan.
36. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (RECORD DRAWINGS): At the conclusion
of the project applicant shall provide digital as-built/record drawings of all
improvements constructed in the public right-of-way or easements in which the City
owns an interest.
37. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (INDEFINITE ENCROACHMENT PERMIT):
An approved indefinite encroachment permit will be required for any private
infrastructure constructed in the public right-of-way, easement or on property in which
the City holds an interest, but that was not authorized by a building permit.
38. PLAN SET CONSISTENCY. The Final Map shall incorporate the drainage changes reflected
in the Architectural Plan set submitted on February 26, 2026 and shall reflect and be
consistent with the requirements and modifications identified in Section 8 of this Record
of Land Use Action.
39. STORMWATER MANAGEMENT PLAN REVISIONS. Prior City permit issuance, the
applicant shall work with the City to revise the stormwater management approach
shown on Sheet C7.1 (Preliminary Stormwater Quality Control Plan). The currently
proposed storm drain infrastructure associated with TCM 8 shall be reevaluated, and an
alternative solution shall be developed to the satisfaction of the City. This may include,
but is not limited to, modifying TCM 8 to utilize infiltration methods and identifying an
alternative means of discharging stormwater from TCM 3. Final design details shall be
subject to City review and approval prior to Final Map approval.
Water-Gas-Wastewater Utilities
40. On Sheet C4.1 – Preliminary Civil Site Plan, and C6.1 – Preliminary Utility Plan, Water
meter shall be relocated so no obstruction is within the 10x10 easement. Refer to
conditional comment in C7_3606 El Camino Real_Plans for location.
41. On Sheet C4.1 – Preliminary Civil Site Plan, and C6.1 – Preliminary Utility Plan, remove
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sewer connection shown on El Camino Real. Refer to conditional comment in C7_3606
El Camino Real_Plans for location. If a secondary sewer connection is needed
connection shall be on Kendal Ave. or Matadero Ave.
42. On Sheet C4.1 – Preliminary Civil Site Plan, and C6.1 – Preliminary Utility Plan, add
Reduced Pressure Principal Assembly (RPPA) to irrigation service per CPAU WGW
Standard WD-11C
SECTION 9. Term of Approval.
1. Architectural Review Application. In the event actual construction of the project is
not commenced within two years of the Effective Date, the approval shall expire and be
of no further force or effect. An extension may be granted in accordance with the
allowances set forth in the municipal code and state law.
2. Vesting Tentative Map. All conditions of approval of the Vesting Tentative Map shall be
fulfilled prior to approval of a Final Map (PAMC Section 21.16.010[c]). Unless a Final
Map is filed, and all conditions of approval are fulfilled within a two-year period from
the date of Vesting Tentative Map approval, the Vesting Tentative Map shall expire and
all proceedings shall terminate. A request for an extension of time may be granted by
the city council after recommendation of the planning commission, after the written
extension request of the subdivider is submitted, prior to the expiration of the Vesting
Tentative Map approval, or any previous extension granted. Such extension(s) shall be
subject to the maximum limitations set forth in the Subdivision Map Act.
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INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST: APPROVED:
_________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED AS TO CONTENT:
___________________________ ___________________________
Assistant City Attorney City Manager
___________________________
Director of Planning and
Development Services
PLANS AND DRAWINGS REFERENCED:
Those plans titled “C7_3606 El Camino Real_PLANS.pdf” consisting of 77 pages, dated and
submitted February 26, 2026.
Those plans prepared by Kier+Wright titled “VESTING TENTATIVE MAP– 3606 EL CAMINO REAL
(25PLN-00232)” consisting of twelve pages, dated and submitted February 3, 2026.
April 13, 2026 www.paloalto.gov
3606 El Camino Real
(Builder’s Remedy) Architectural
Review, Vesting Tentative Map
Presenter:
Steven Switzer, Senior Planner
Zoning:
(CN) Neighborhood Commercial
(CS) Service Commercial
(RM-30 & RM-40) Medium Density
Multiple-Family Residence District
Adjacent Land Uses:
•Commercial
•Residential
PROJECT LOCATION
February 15, 2024 Senate Bill (SB) 330 pre-application submitted (24PLN-00047)
June 10, 2025 Major ARB application submitted (24PLN-00162)
December 4, 2025 ARB (Early Feedback)
September 22, 2025 Applicant requested consideration under Assembly Bill (AB) 130
(Public Resources Code Section 21080.66)
February 11, 2026 PTC (Recommended Denial 3-2-1)
April 13, 2026 City Council
BACKGROUND
•Recommended Denial (3-2-1) based on Subdivision Map Act Finding #6: “…the design of
the subdivision or type of improvements is likely to cause serious public health problems”
•bicyclists and pedestrians safety concerns with safe routes to school.
•Additionally, the PTC recommended City Council consider the following:
•Project and cumulative traffic safety analysis;
•Providing sidewalk easements;
•Relocating ingress/egress to improve pedestrian and bicycle safety and reduce
congestion near El Camino Real intersections; and
•Incorporating portions of the site for a bike path.
*Of the items listed above, the applicant incorporated sidewalk easements into the proposal.
BACKGROUND (February 11, 2026 – PTC Recommendation)
PROJECT OVERVIEW
•Demo 12,572 sf of commercial space across seven (7) parcels
•Demo 38 residential units
•Seven (7) stories high (83 feet tall)
•Total of 321 Units:
•Studio (54 Units)
•1 Bedroom (109 units)
•2 Bedrooms (119 units)
•3 Bedrooms (39 Units)
•37 BMR units (>13% minimum), Affordable to 50-80% AMI
•391 parking spaces (321 EV) (45 Tandem)
•280 long term bike spaces
•Vesting Tentative Map (Merging seven parcels)
STATE LAW CONSTRAINTS
•“Builder’s Remedy” project as defined in Assembly Bill (AB) 1893.
•The project may not be denied based on inconsistency with the
Zoning Ordinance or Comprehensive Plan land use.
•The project could be denied on finding a specific adverse impact
on public health or safety that cannot be mitigated or avoided.
•The City may only require compliance with objective standards
that would apply to the project if it were proposed on a site that
allows the density requested.
•This project, with a proposed 3.49:1 overall FAR and 128 du/ac
density, would be permitted in the El Camino Real Focus Area.
•State Density Bonus Law allows the applicant waivers and/or
concessions from applicable standards.
•AB 130 exempts infill housing projects from CEQA and sets strict
timelines for City review and decision.
•(Informational Purposes only)Conformance with:
•El Camino Real Focus Area Development Standards
•Objective Design Standards
•El Camino Real Design Guidelines
STATE LAW CONSTRAINTS
PUBLIC COMMENTS
•Key comments include:
•Driveway locations on side streets (Matadero and
Kendall Ave)*
•Potential impacts to safe routes to school.*
•The public benefit of delivering housing (300+ new
rental units).
*A Transportation Analysis is included as a condition of
approval.
REVISED RECORD OF LAND USE
•Section 8 Conditions of Approval require the Final Map to
reflect the latest updated Architectural Review Plans and
outstanding off site drainage improvements.
•Added Condtion of Approval for public access easement
extension along Matadero Avenue:
Easement Extension. The public access easement along
Matadero Avenue will extend to the building facade, taking
into account any architectural projections and as-built
construction tolerances.
CEQA STATUS
Exempt Pursuant to Assembly Bill (AB) 130 (Public Resources
Code Section 21080.66).
•Statutory Exemption
•Permanent five (5) hearing limit on housing projects
•Sets timelines for Tribal Consultation
(60 days or 135 days)
•30 days to approve/disapprove projects after Tribal
Consultation
RECOMMENDATION
Staff Recommends that City Council:
1.Consider the project exempt from California Environmental Quality Act (CEQA) in
accordance with Assembly Bill (AB) 130 (Public Resources Code Section 21080.66); and
2.Approve the Major Architectural Review and Vesting Tentative Map applications based
on findings and subject to conditions of approval in the Revised Draft Record of Land Use
Action (RLUA) in Attachment B.
STEVEN SWITZER
Senior Planner
Steven.Switzer@PaloAlto.gov
650-329-2321
3606 El Camino Real
City Council Meeting
April 13th, 2026
Introduction
Architect: BDE Architecture
•Local firm with over 37 years of experience in the Bay Area
Landscape Architect: The Guzzardo Partnership
•Local firm with over 62 years of experience in the Bay Area
Civil Engineer: Kier & Wright
•Local firm with over 53 years of experience in the Bay Area
Development Advisors: Sares Regis Group of Northern California
•Deep experience in building successful, well-conceived multi family buildings
Property Owner: Giovannotto Family
•Multi-generational Palo Alto residents that have owned the land for over 20 years
Building Homes for Families
3606 ECR Community Benefits
•Delivers 321 new homes, including 37 affordable units, helping
address Palo Alto’s housing shortage
•Advances Palo Alto’s RHNA housing goals and Housing Element
commitments
•Provides diverse housing options, from studios to 2- and 3-bedroom
family units
•Improves the pedestrian experience along El Camino Real, Matadero
and Kendall
•Helps build Palo Alto’s vision for housing on El Camino Real
Alignment with Focus Area Goals
The City put forth a vision for El Camino Real that established urban
design principles and guidelines for future projects to create a
coherent and attractive corridor that supports Palo Alto’s housing
goals.
In our project, we see an alignment with the goals and many of the
objective standards of the El Camino Focus Area:
100%
Housing
Project
Building Scale
and Density
Below the
FAR limit
Shields visibility
of parking from
ECR
Exceeds
Parking
Requirements
Includes
Facade
Variation
Enhanced
Ground Floor
Experience
Provides
Affordable
Housing
An Infill Site with Excellent Transit Access
Current: Bus Kiosk On Site. Protected Bike Lane on El Camino. Extensive Work-from-Home
facilities within the Project.
Future: Palo Alto Bicycle and Pedestrian Transportation Plan (BPTP) would further enhance
transportation in the El Camino Focus Area.PROTECTED BIKE LANE (CLASS 4)
Existing Pedestrian Experience
Design 1 – SB 330 App, February 2024
Design 2 – Full Planning Application
Final Design – Submitted March 2026
ARB Feedback: Building Articulation
ARB Feedback from December 2025
The ARB encouraged additional façade and roofline modulation to more clearly articulate
changes in plane and strengthen the building’s visual character.
Existing Condition
ARB Feedback from December 2025
ARB members suggested that the Kendall-facing façade would benefit from a more prominent
expression of the second pedestrian lobby, in keeping with the primary lobby.
ARB Feedback: Kendall Facade
ARB Feedback : Open Space and Transition
ARB Feedback:
Recommended,
expanded roof
decks, and
improved usability
of shared open
spaces, and
strategies to visually
soften transition to
neighborhood.
Distributed Vehicle Egress: 2 Access Points
Located Per Palo Alto
Project Standard:
Palo Alto's Objective Design
Standards (ODS
18.24.030(D)) states that
"vehicle access shall be
located on alleys or side
streets where available".
An infill site with the rare
opportunity to distribute
vehicle egress through two
separate points of egress,
helping to minimize
potential neighborhood
effects.
1
2
Sight Lines:
Increased the
sight lines to
ensure cars can
see 200 ft in
either direction
during egress
from the
garage.
El Camino Real
200 Foot Sight Lines at Both Egress Points
20
0
F
e
e
t
20
0
F
e
e
t
Figure 1: Calculated Sight Line Distances at Vehicle Egress Points
20
0
F
e
e
t
20
0
F
e
e
t
Ke
n
d
a
l
l
A
v
e
n
u
e
Ma
t
a
d
e
r
o
Av
e
n
u
e
1
2
Conclusion
321 New
Apartment Homes,
including 37
Affordable Units.
Add Vitality to
the El Camino
Corridor
Contributes to
Palo Alto’s
Housing Vision
Architectural Review Board
December 4th, 2025Thank you!
Architectural Review Board
December 4th, 2025Appendix
Delivery, Drop Off, Pick Up Functions
Pick Up/
Drop Off Zone
Trash stored
inside, pulled to
Kendall for pick
up day
Move in
loading
zone
Schedule: 321 New Homes in 2029
2026 2027 2028 2029 2030
Entitlements
Design Development +
Construction Docs
Building Permit
Construction
City Council
Hearing
Construction
Starts
Next Steps:
Following approval, we expect construction to begin in 2027, and 321 new
homes delivered in late 2029.
New homes
delivered
Proposed Street Experience - Kendall
Currently there are no sidewalks along this stretch of Kendall, includes in
the proposed design are tree-lined sidewalks that provide a safe and
convenient gateway to the neighborhood.
El Camino Real
El Camino Real
Proposed Street Experience - Matadero
The corner of Matadero and ECR will be improved to include spacious
sidewalks, additional street trees, and native landscaping, and will be lined
with lobby and amenity uses that activate the ground floor.
El Camino Real
El Camino Real
Enhanced Pedestrian Experience
Activates the pedestrian experience along El Camino Real with:
•Storefront windows and active ground-floor amenities.
•Landscaped setbacks, seating, and pedestrian-scale lighting.
•Double-height lobby with visual street connection.
•Streetscape improvements promoting walkability.
PTC Feedback: Audio and Visual Signals
Audio and Visual
Queue:
"Car Coming" sign
flashes and warns
pedestrians, cyclists
when car approaches
exit
Architecture:Elevations and Materials
Architecture:Character & Design
Site Circulation
Sustainability & Building Performance
•All-Electric Building – No natural gas
•Solar equipped roof
•EV charging infrastructure for all units
•Enhanced energy and water efficiency
•Native and drought tolerant plants
•100% Stormwater Treatment
•Bike parking with repair station + ECR Bus Line
to encourage alternative mode of transit
•Construction Carbon Footprint Reduced
Landscape: Materials and Plants
From:Adam Schwartz
To:Council, City
Subject:YES to new homes at 3606 El Camino Real (Agenda Item #8)
Date:Monday, April 13, 2026 9:53:00 AM
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To the Palo Alto City Council:
My name is Adam Schwartz. I’ve lived in Palo Alto for a decade in the
University South neighborhood.
Please vote to approve the application to build 321 new homes at 3606 El
Camino Real. This is Agenda Item #8 for the City Council's Regular
Meeting on April 13.
These new homes can accommodate all kinds of people:
-People earning below the area median income can live in the 37 homes
set at below-market rates.
-Families with kids can move into the homes with two and three
bedrooms, which are about half of the total homes.
-Our older neighbors now living in a detached single-family home can
downsize into a new apartment in their home city, and make room for a
new family in their old home.
-Our children and parents can live near us in these homes.
-Our civil servants and service workers can live near their jobs in these
homes.
This is a great location for new homes:
-The VTA bus line #22 has a stop near the site.
-The CalTrain at California Avenue is 1.2 miles away.
-There is a new protected bike lane right in front on El Camino Real.
- There are nearby restaurants, schools, and jobs.
I appreciate all the hard work being done by our city council and city staff
to build more homes in our community.
Sincerely,
Adam Schwartz
University South
From:Mircea
To:Council, City
Cc:Switzer, Steven; pafd@cityofpaloalto.org; Lindsey, Stephen; Reifschneider, James; Transportation; Alison Rivera;
John King; Kristan Green; Dror Katzav; Yu Wang; Liberman, Art; CHaggerty@valleywater.org; Kellie Stafford
Subject:COMPREHENSIVE OPPOSITION TO PROJECTS 25PLN-00243 & 3400 ECR - Monday April 13th 2026 City Council
Agenda
Date:Tuesday, April 7, 2026 10:07:09 PM
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Grounds for Denial: Unmitigable Threat to Public Safety, Emergency Access, and
Riparian Integrity
TO: Palo Alto City Council; Architectural Review Board; Planning Department
FROM: Barron Park resident and property owner since 2006: 572 Chimalus Dr. Palo
Alto, CA, 94306
I. Executive Summary
This letter serves as a formal objection to the 7 parcels merger and development as
submitted at 3606 El Camino Real. Under Gov. Code § 65589.5(d)(2), we contend
these projects create a specific, adverse impact on public health and safety that
cannot be mitigated. The "traffic dump" from 3606 and 3400 ECR (combined 1,500+
daily trips) onto the Matadero Road bottleneck will physically obstruct emergency
response and endanger student commuters on a verified high-injury corridor.
II. 20-Year Traffic Safety & Accident Data Integration
The intersection of El Camino Real (ECR) and Matadero Road is an established
danger zone. In the last 20 years driving the Matadero/Barron Park stretch several
times a day, I have seen the Palo Alto Fire/Ambulance department attending to a
biker at the corner of ECR and Matadero-CreekSide Inn corner averaging several
times a quarter. Those records are real.
High-Injury Network (HIN): A 2024 city-commissioned study found that 14% of all
Palo Alto crashes occur on ECR, which comprises only 4% of the city's roads.
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20-Year Collision Trends: Over the past two decades, one-third of all bicycle and
pedestrian accidents in Santa Clara County have occurred on the Palo Alto
segment of ECR.
Vulnerability of Minors: Matadero Road is a designated Safe Route to School.
Historical data shows an average of one injury every month on the Palo Alto ECR
corridor, frequently involving children and teenagers.
Recent Conflicts: As recently as 2024, ECR has been flagged by Caltrans as
particularly prone to bike crashes. Introducing massive vehicle volume into this exact
"Safe System" plan area directly violates the city's duty to protect student commuters.
III. Emergency Response Jeopardy (Barron Park Access)
Matadero Road is a Major Street Connector for the Barron Park neighborhood.
Blocking this artery will delay life-saving Fire, Police, and Ambulance services.
PAFD Performance Decline: The Palo Alto Fire Department (PAFD) 90th percentile
response time was 9:16 in 2024, failing to meet the city's 8-minute safety target.
Physical Obstruction: The 3606 ECR driveway sits within 100 feet of the
ECR/Matadero corner. The resulting vehicle queuing will gridlock Matadero Road,
physically preventing emergency units from Station 4 (already under-staffed
via cross-staffing) from reaching Barron Park residents during medical emergencies.
No Feasible Mitigation: There is no engineering solution exists to widen the
Matadero Road creek crossing without destroying the protected riparian corridor.
IV. Matadero Creek & Environmental Safety Reasons for Denial
Riparian Integrity: The project footprint sits within 100 feet of the Matadero Creek
bank. This proximity violates the intent of the Stream Corridor Protection
Ordinance and risks bank failure.
Flood Hazard (PAMC 16.52): Subterranean parking for nearly 400 cars near an open
creek bank creates unmitigable hydrostatic pressure risks during flood events.
Ecological Impact: The cumulative density and runoff from both projects pose a
"quantifiable risk" to the creek's habitat and downstream flood capacity.
V. Final Legal Conclusion
The Planning and Transportation Commission (PTC) already voted 3-2 to recommend
denial based on these "serious public health problems." We urge the City Council to
prioritize Safe Routes to School and Barron Park emergency access over
inappropriate density and the City Council should grant no project driveways that
would dump more cars on Matadero Rd. when El Camino Real Driveway Access
exists and is implementable today. Developer cares more about the building's
appearance on ECR —which resembles a shoebox anyway—than the integrating a
driveway on ECR which will protect the safety of Barron Park school children,
residents' daily traffic and emergency responders.
As a Barron Park property owner and resident since 2006, I urge you to deny the size
of this project and demand that driveways be placed on El Camino Real. Builder's
remedy does not override the safety and health of Palo Alto residents; this is a clear
fact and finding here. Stand up for Palo Alto residents who elected you to protect us
while building safe housing.
I want you to be left with reading this article and think what you will be voting for:
Two Fatal Collisions in Palo Alto and Los Altos Hills within a Week — Silicon Valley
Bicycle Coalition
Per the article link above: "Over the past decade, one-third of bicycle and
pedestrian accidents in Santa Clara County have occurred on El Camino Real in
Palo Alto. Shockingly, this statistic translates to an average of one person,
often a child or teenager, being injured each month in Palo Alto."
Thanks
Mircea Voskerician
572 Chimalus Dr. Palo Alto
Actionable Steps for Council Members
Request a Police/Fire Department/Ambulance Response Records Audit:
Formally request a 20-year collision log specifically for the ECR/Matadero corner.
This will be an eye-opener.
Mandate a Cumulative Access Study: Model the simultaneous "morning peak" and
" evening peak" output and input from both development driveways including 3400
ECR (existing hotel or new proposed development) on Matadero Road.
From:John King
To:Council, City
Subject:Barron Park Association letter re :3606 El Camino
Date:Wednesday, April 8, 2026 4:06:40 AM
Attachments:BPA_Letter_re_3606 El Camino.pdf
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Dear Palo Alto City Council,
Please find a letter approved by the Barron Park Association board regarding the proposed
3606 El Camino Real, Palo Alto development.
Please include for the upcoming council discussions about the neighborhood concerns
of the proposal.
Respectfully submitted,
John W. King
President
Barron Park Association
724 Barron Avenue
Palo Alto, CA. 94306
Johnwadeking@gmail.com
650-483-2710
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1
Dear Palo Alto City Council,
The Barron Park Association Board of Directors is writing to express neighborhood concerns
regarding the proposed development at 3606 El Camino Real. We agree with the Planning and
Transportation Commission’s recent decision not to approve the proposed lot consolidation due
to the lack of sufficient information related to its suitability.
Our primary concern focuses on traffic and safety. Entrances and exits for the 321-unit
development should not be located on Barron Park’s small, residential streets. Given the
magnitude of this project — representing approximately a 20% increase in Barron Park’s
residential density — access points must be placed on El Camino Real rather than on narrow
neighborhood streets. Barron Park includes narrow, single-lane streets, many without sidewalks
or shoulders. These streets cannot safely accommodate a substantial increase in vehicular traffic
seeking to bypass gridlocked intersections near the proposed development’s side-street
driveways. (See the example photos below.)
Matadero Avenue is designated as a Safe Routes to School corridor, a Palo Alto Bike Boulevard,
and an Emergency Vehicle Access Route. Maintaining safety and accessibility on Matadero and
its feeder streets is critical. Increased congestion from a large development would directly
compromise pedestrian, cyclist, automobile, and emergency vehicle safety.
Barron Park also faces unique infrastructure limitations. Vehicular access is restricted on the
north and west by Stanford Research Park, Rivian, Varian, Bol Park, and the VA Hospital.
Matadero and Los Robles serve as primary entrances and exits, yet both dead-end at Bol Park
and the VA. In emergency situations, these constraints present serious concerns. Large-scale
projects must include plans that do not further restrict emergency access.
2
The neighborhood remains burdened by overhead utility wires, increasing fire risk in an area
already constrained by limited evacuation routes. Adding significant density without addressing
this vulnerability exacerbates safety risks to current residents who have very limited emergency
exits from Barron Park.
Additionally, the intersection of El Camino and Matadero is already hazardous. Traffic now
frequently backs up onto El Camino, blocks crosswalks, and creates gridlock conditions. This
would worsen with the primary driveway for 3606 ECR less than 100 ft from the intersection.
There is, of course, no right turn on red in either direction. Introducing additional vehicle volume
from a 321-unit development will worsen congestion and heighten safety risks for pedestrians,
cyclists, and drivers.
While the City anticipates reduced automobile use due to proximity to ECR, this has not been the
experience in Barron Park. Over the past twenty years, automobile traffic has steadily increased.
Streets adjacent to ECR are routinely fully parked overnight. Despite an active cycling
community, most residents rely on cars for employment, groceries, medical care, schools, and
daily needs. Reliable alternative transportation options remain limited.
We respectfully urge the Council to ensure that:
1.All resident entrances and exits be located on El Camino Real.
2.Emergency access and evacuation constraints be addressed prior to approval.
3.Infrastructure and fire safety risks be mitigated.
4.Architectural design strive to be compatible with the existing neighborhood and
design standards per the ARB request for improvements to the building front face.
5.Appropriate setbacks, terracing, and landscaping be incorporated to create
meaningful transition zones between higher-density buildings and smaller nearby
residences.
3
Palo Alto has demonstrated that new developments can be thoughtfully integrated into
established neighborhoods. We rely on the City Council and City Commissions to approve
projects that enhance, rather than compromise, the safety and character of Barron Park for both
current and future residents.
Thank you for your consideration.
Sincerely,
Board of Directors of the Barron Park Association
bpapaloalto.org
Example on a Typical Day: Matadero Avenue Opening Onto El Camino
Location of photos: Matadero Avenue with ECR in the background. The proposed apartment
driveway is approximately where the brown UPS truck is parked (on the right).
Notice the absent shoulder on the north side of Matadero (on the left in both photos), and the
unsafe pedestrian/cyclist zone on the south side (on the right in both photos) due to parked cars.
It is not unusual to have one lane blocked by a mail or delivery truck. As a designated Safe Route
to School, Palo Alto Bike Boulevard, and an Emergency Vehicle Access Route, bikes may take
the lane with autos, but this is especially hazardous to young children inexperienced with traffic.
Also, notice that cars passing large, parked delivery trucks (here, UPS and Amazon) must use
both lanes for pedestrian safety. As you see in the photo on the right, the white car approaching
us has moved into the opposite lane to avoid a parked truck.
4
From:Penny Brennan
To:Council, City
Subject:Please Vote "NO" on Approval of the 3606 El Camino Project
Date:Wednesday, April 8, 2026 4:28:14 PM
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Dear Councilmembers,
I urge you to vote "NO" on approval of the 3606 El Camino project.
Each time I read the letters, and listen to the presentations, of the developers and supporters of
this project, I have to wonder whether they have ever personally visited the site of the
proposed project, including personally walking or driving along the streets that border it,
especially during early morning and late afternoon commute times. Historically, the project's
developers have paid little attention to potential negative impacts of this very tall, very high-
density building on its surrounding environment, especially its negative traffic and safety
impacts on Barron Park and Ventura residents. In my opinion, City Council should not
approve this project until the negative traffic and safety impacts of this project are thoroughly
understood and then mitigated through correction of the building's current design flaws.
In earlier letters I detailed my concerns about traffic and public health and safety hazards
posed by the ill-siting of the building's main ingress/egress (on narrow, busy Matadero
Avenue). Another ingress/egress of concern is sited on Kendall Avenue, at the other side of
the building. All of the building's garbage/recycling/compost pick-ups are planned to occur
there. At the Architectural Review Board meeting developers told us that there would be
garbage pick-ups two times a week from the Kendall side of the building. (Which is, perhaps,
an underestimate, given > 1,000 people will reside in the building?) A twice-weekly pick-up
practice would entail six refuse truck pick-ups per week: two each for landfill, recycling, and
composting disposal. Even a minimum twice-weekly pick-up practice will frequently block
traffic, and endanger bicyclists and pedestrians, on the very narrow, twisting Kendall Avenue
six times a week. The landfill, recycling, and composting trucks will have no easy way of
turning around to return to El Camino and will make their way through Barron Park streets in
the early morning, possibly corresponding with student bicyclists and pedestrians making their
way to the Barron Park Elementary, Fletcher Middle, Gunn High, and other schools in the
Barron Park neighborhood. This consideration underscores the importance of a thorough
traffic safety analysis of the proposed 3606 El Camino project and provides another public
health and safety grounds for City Council to oppose the 3606 El Camino project.
In an email dated January 19, 2026, I asked Albert Yang, Palo Alto City Attorney, about
public safety as legal grounds for the City of Palo Alto to oppose the 3606 El Camino
Builder's Remedy project. Paragraph 5 of his March 31, 2026 email response states, "...In the
case of the hazards to bicyclists and pedestrians, the City’s Office of Transportation has not
identified any objective, written public health or safety standards that the project violates." My
response to that statement is: Of course it has not. To my knowledge, the City's Office of
Transportation has never vetted the 3606 El Camino project for violation of public health or
safety standards. I think that City Council should request that the Office of Transportation do
so, and that it should furthermore formulate objective, written public health and safety
standards that can be used by the City to protect residents of Palo Alto from serious
transportation-related public health and safety violations such as those posed by the 3606 El
Camino Builder's Remedy project.
Thank you for considering my concerns.
Sincerely,
Penny Brennan, PhD
Ventura Neighborhood
From:Simon Manka
To:Council, City; City Mgr
Subject:Support for 3606 El Camino Real Housing Project
Date:Wednesday, April 8, 2026 5:18:29 PM
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Dear Palo Alto City Council,
I am writing to express my support for the proposed housing development at 3606 El Camino
Real.
Palo Alto urgently needs more housing, and this project is exactly the kind of infill
development the city should be encouraging. Adding new multifamily homes along a major
corridor like El Camino Real is a smart way to create more housing opportunities while
making efficient use of existing urban land.
I appreciate that this proposal would replace underutilized properties with a substantial
residential project that can help address the city’s housing shortage. Thoughtful projects like
this are important to Palo Alto’s long-term future, affordability, and sustainability.
I encourage the City Council to approve the 3606 El Camino Real project.
Thank you for your time and consideration.
Sincerely,
Simon Manka
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From:Melanie Bentley
To:Council, City
Cc:Switzer, Steven
Subject:3606 El Camino Real Support
Date:Thursday, April 9, 2026 11:44:53 AM
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To the Members of the Palo Alto City Council,
My name is Melanie Bentley and I am writing in support of3606 El Camino Real. I work locally as a
nurse at Stanford in the Pediatric ICU, and one of the most common issues I hear about from new
staff is the lack of housing options in the area.
My colleagues and I work long and stressful hours, and many of us also face the additional burden of
a long commute. There is a real need for quality, local housing options that are near our work and
provide the kind of wellness amenities that help us decompress after a shift.
Having a modern, reliable place to live close to the hospital would make a world of difference for the
healthcare community. It allows us to focus on our patients rather than the time spent in traffic, and
it helps our staff feel more connected to the community we serve. This project is a sensible use of
the El Camino corridor and provides exactly the type of housing we need to support our local
workforce. I hope you will approve this development on Monday.
Sincerely,
Melanie Bentley
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From:Amy Thomson
To:Council, City
Subject:Support for 3606 El Camino Real
Date:Thursday, April 9, 2026 2:14:54 PM
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Palo Alto city council,
My name is Amy Thomson and I'm the policy director for the Silicon Valley Bicycle
Coalition. One of our priority campaigns over the last 20 years has been reimagining El
Camino Real to be a complete street with abundant and affordable housing.
Please vote to approve 3606 El Camino Real, which will bring much-needed family friendly
apartments to our community. The shortage of homes in San Mateo County and the state hurts
our vulnerable residents first and foremost. We need to support homes along transit- and
resource-rich corridors like El Camino Real in Palo Alto.
Thank you for your vote to support the future Bay Area we deserve - one with safe streets and
access to homes.
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From:Tony Montini
To:Council, City
Cc:Switzer, Steven
Subject:3606 El Camino Real
Date:Thursday, April 9, 2026 2:57:18 PM
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To the Palo Alto City Council and Staff,
I am writing to express my support for the 3606 El Camino Real project. Although I reside in
San Jose, for my entire life Palo Alto has been an extension of my hometown.
I have great memories in Palo Alto, including happy hours at Miyake’s, sports at the Old Pro,
and trivia nights at the Nut House. I now understand that there is a lack of newer, high-
quality housing options. I still visit frequently, and when a friend mentioned that there was a
new housing project being proposed, I wanted to make my voice heard. Sadly, many of the
businesses I mentioned have since closed, but I believe that when you bring in a new
generation of young professionals (which happens when you create new housing), you
create the customer base needed for new and hip businesses to emerge.
By approving this project, you are creating a reason for the next generation of professionals
to stay in Palo Alto rather than looking elsewhere for modern housing, as I did. I hope to
see this project move forward.
Sincerely,
Tony Montini
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From:Art Liberman
To:Council, City
Subject:Reject 3606 El Camino unless the developer makes changes
Date:Thursday, April 9, 2026 3:33:41 PM
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Council -
The plans for 3606 El Camino indicate the entry and exit from parking for all the
apartments going onto neighboring streets and not onto El Camino. Please ensure
that the developer revises the plans to have entrances and exits on El Camino. The
Creekside Inn project, across Matadero Avenue from this project, initially had exit and
entrance from the parking on Matadero Avenue, but they changed their plans to have
entrance and exit from El Camino. something similar needs to change for this project
as well. Please do not approve this project in its current form.
Matadero Avenue is a narrow street with one traffic lane in each direction. It is a
collector street, being one of only two streets that go in and out of Barron Park with
signalized intersections on El Camino. Furthermore, Matadero Ave.is a designated
Bicycle Boulevard by the City of Palo Alto Office of Transportation. The plans indicate
that the other entrance and exit from the parking for this project is proposed to be on
Kendall Ave., which is also a very narrow street. Both Matadero Ave and Kendall Ave
are classified as "safe routes" for children who walk and ride bikes to and from Barron
Park School. Here is a link to a pdf of the map. barron-park-elementary-walk-roll-map-
2022.pdf). While the Builder has proposed these plans as 'builder's remedy',
California state laws state that the safety of individuals is paramount.
The possibility of likelihood of serious congestion at the intersection of Matadero Ave
and El Camino has created concern among residents in Barron Park. Because of the
Bicycle Lanes on El Camino, the City of Palo Alto has instituted No Right Turn on
Red at this and every signalized intersection with El Camino. Unless this housing plan
is changed, i think you and anyone with any knowledge of the neighborhood would
know that the backup and gridlock on Matadero Avenue would become horrendous
each and every morning! The roadway would become paralyzed. In fact, it could
become so bad that people living at 3606 El Camino may not be able to leave their
apartments.
The developer has created these plans without any meetings or discussions or
interactions with the residents of the Barron Park neighborhood. The BPA Board has
written a long and thoughtful letter to the Council, opposing the plans.
Thank you all for your service to residents of Palo Alto.
Art Liberman
Resident of Barron Park and
member of PABAC
From:Bill Fitch
To:Council, City
Subject:Agenda Item 8:
Date:Friday, April 10, 2026 9:52:03 AM
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i
Hello Palo Alto city council, my name is Bill Fitch and I live in Evergreen Park.
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly
apartments to our community. I also support the city making additional transportation
improvements around the project, such as improved bike infrastructure, but I do not think
those should impact the project moving forward.
.
Thank you for supporting more homes in our community,
Bill Fitch
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From:Barb V
To:Council, City
Subject:Agenda Item 8: supporting multi-family housing
Date:Friday, April 10, 2026 9:52:43 AM
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i
Hello Palo Alto city council, my name is Barb Voss and I live in Palo Alto Redwoods (4250
El Camino Real).
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly
apartments to our community. I also support the city making additional transportation
improvements around the project, such as improved bike infrastructure, but I do not think
those should impact the project moving forward.
I know first-hand the struggle for educators like me to find housing in Palo Alto, as I recently
went through a housing transition. The location of the proposed housing is great - accessible to
transit and central to major services. It will be a great addition to the El Camino corridor and
contribute to the continued revitalization of this area.
Thank you for supporting more homes in our community,
Barb Voss
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From:Pat Kinney
To:Council, City
Subject:Agenda Item 8: [INSERT PUBLIC COMMENT TITLE]
Date:Friday, April 10, 2026 10:00:39 AM
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Esteemed Palo Alto City Council,
My name is Patricia Kinney and I live in the Duveneck/St Francis neighborhood, formerly in the Ventura
neighborhood.
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly apartments to our
community. I also support the city making additional transportation improvements around the project, but I do not
think those should impact the project moving forward.
This location is close to transportation, parks and schools, and would be an ideal location for families.
Thank you for supporting more homes in our community,
Patricia Kinney
From:Fred Kohler
To:Council, City
Subject:Agenda Item 8: [INSERT PUBLIC COMMENT TITLE]
Date:Friday, April 10, 2026 10:19:12 AM
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Hello Palo Alto city council, my name is [INSERT NAME] and I live in [INSERT NEIGHBORHOOD].
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly apartments to our
community. I also support the city making additional transportation improvements around the project, such as
improved bike infrastructure, but I do not think those should impact the project moving forward.
[CUSTOMIZE HERE WITH WHY YOU CARE OR DELETE].
Thank you for supporting more homes in our community,
[INSERT NAME]
Sent from my iPad
From:Lori wainen linberg
To:Council, City
Subject:Agenda Item 8: [Please support more affordable housing
Date:Friday, April 10, 2026 10:08:07 AM
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on links.
Hello Palo Alto city council, my name is Lori Linberg
and I live in Palo Alto
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly apartments to our
community. I also support the city making additional transportation improvements around the project, such as
improved bike infrastructure, but I do not think those should impact the project moving forward.
Presently, in our area, EMTs, ER technicians, surgical technicians, radiological technicians, phlebotomist, CNA‘s,
childcare workers, teachers, teachers, assistants and janitors, as well as many other fields cannot afford housing in
the area. We cannot afford communities without these important services. They deserve to have a home where their
children can grow up with Hope and a place to play outside in the same joys that everyone else has. They are
contributing to the well-being of our communities and we would be lost without them and we’re losing them on a
regular basis. In fact, we’re even losing doctors in the area because of the high cost of living.
Thank you for supporting more homes in our community,
Lori W Linberg
Sent from my iPad
From:Rob Schreiber
To:Council, City
Subject:Agenda Item 8: Approval of 3606 El Camino housing development
Date:Friday, April 10, 2026 10:29:23 AM
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The project at 3606 El Camino has so much going for it.
It has a builder who can and will build it; it "pencils out".
It addresses parking.
It will replace a completely underused, blighted stretch of the depressing,
embarrassing South Palo Alto El Camino.
It will bring over 300 younger, less wealthy individuals and families into our ever more
economically homogeneous city, add demand for retail and services, reduce the
commute times for these new residents, and add students to the public schools,
which should continue to be at the core of what makes this city special.
Please vote to approve it. No objection based on bicycling or other secondary
considerations should be allowed to delay or derail it. We need housing and we
need investment and we need redevelopment of antiquated decaying streets. We
need these things now.
Thank you for considering these things before deciding.
Rob Schreiber
(A resident of Greenmeadow)
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From:bitew tisase
To:Council, City
Subject:Agenda Item 8: [INSERT PUBLIC COMMENT TITLE]
Date:Friday, April 10, 2026 10:39:37 AM
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!
Dear Members of the City Council,
I am writing to express my strong support for the proposed housing
development that includes 321 homes, with 122 two-bedroom units and 38
three-bedroom units.
This proposal represents an important opportunity to provide much-needed
family-sized housing in our community. Too often, new developments
focus primarily on smaller units, leaving limited options for families who
wish to live and grow in our city. By including a significant number of two-
and three-bedroom homes, this project helps address that gap and supports
a more inclusive and balanced community.
I am concerned that the Planning Commission recommended denial despite
the project being consistent with state housing law. Moving forward with
this development would not only align with those legal requirements but
also help the City avoid potential legal risks. More importantly, it would
demonstrate a commitment to planning for future generations and ensuring
that families of all sizes have the opportunity to live here.
Family-friendly, multi-family housing is both necessary and achievable,
and this project is a clear example of that potential. I respectfully urge the
City Council to approve this proposal and take a meaningful step toward
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expanding housing opportunities in our community.
Thank you for your time and consideration.
Sincerely,
BITEW Tisase
From:Susan Setterholm
To:Council, City
Subject:Agenda Item 8: [INSERT PUBLIC COMMENT TITLE]
Date:Friday, April 10, 2026 10:46:09 AM
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on links.
Hello Palo Alto city council, my name is Susan Setterholm] and I lived in the Greenbrae.
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly apartments to the
community. I also support the city making additional transportation improvements around the project, such as
improved bike infrastructure, but I do not think those should impact the project moving forward.
I want my son to be able to live in Palo Alto and educate his family in the school district.
Thank you for supporting more homes in the community,
Susan Setterholm
From:Gina Dalma
To:Council, City
Subject:Agenda Item 8: [INSERT PUBLIC COMMENT TITLE]
Date:Friday, April 10, 2026 11:19:41 AM
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Hello Palo Alto city council, my name is Gina Dalma and I live in Midtown. Please vote to
approve 3606 El Camino Real, which will bring much-needed family-friendly apartments to
our community. I also support the city making additional transportation improvements around
the project, such as improved bike infrastructure, but I do not think those should impact the
project moving forward.
We need more affordable housing in our community to ensure it remains vibrant and diverse.
Gina D. Dalma
e: gina@dalma.org
p: (980) 722.2660
Let’s connect on LinkedIn: http://www.linkedin.com/pub/gina-dalma/0/53/b47/en
From:Sarah J. Bell
To:Council, City
Subject:Agenda Item 8: Please approve 3606 El Camino
Date:Friday, April 10, 2026 12:41:04 PM
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i
Hello Palo Alto city council, my name is Sarah Bell and I've lived in Palo Alto on and off
since 2005.
When I first arrived in Palo Alto, you could rent a really nice two-bedroom apartment in
downtown for 1,800 a month. Nowadays, a one bedroom will easily cost double that amount.
We need to build more housing so that the next generation of college grads and young families
can afford to live here.
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly
apartments to our community. I also support the city making additional transportation
improvements around the project, such as improved bike infrastructure, but I do not think
those should impact the project moving forward.
Thank you for supporting more homes in our community,
Sarah Bell
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From:Cara Silver
To:Council, City
Subject:Agenda Item 8: 3606 El Camino
Date:Friday, April 10, 2026 12:49:05 PM
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i
Hello Palo Alto city council, my name is Cara Silver and I live in the midtown neighborhood.
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly
apartments to our community. I also support the city making additional transportation
improvements around the project, such as improved bike infrastructure, but I do not think
those should impact the project moving forward.
We so desperately need more housing —anywhere it can be accommodated— for our seniors,
our children and young families moving to the area. Development costs are skyrocketing and
development grinding to a halt. Please do not impose additional costs on a ready and able
developer.
Thank you for supporting more homes in our community!
Best,
Cara Silver
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From:slevy@ccsce.com
To:Council, City
Cc:Armer, Jennifer; Raybould, Claire; Sauls, Garrett; Lait, Jonathan
Subject:3606 ECR
Date:Friday, April 10, 2026 2:02:43 PM
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Dear Mayor Veenker and council members,
I write in support of the staff recommendation and in strong support of this project.
The applicant has a long-time local housing presence in Palo Alto, a strong positive
reputation for caring about the long-term future of our city and has been receptive
whenever possible to suggestions during this proposals road to council.
As you know, the project will provide more than 300 units in a location designated by the
city for higher density housing.
Additional pluses are that all the BMR units will be for low income residents, a substantial
number of larger units and the project will have additional amenities.
I listened to the PTC hearing and am aware of the stated concerns.
The staff report lays out clearly why an El Camino garage entrance is a poor idea.
While residents are entitled to their personal perspective on safety issues, I believe the
applicant has addressed how the garage entrances and exits can be safely managed for
pedestrians and bikers.
I encourage you to continue the council's recent strong support of housing that meets the
goals set out by the city.
This proposal deserves our support.
Stephen Levy
From:Beau Heidrich
To:Council, City
Cc:Switzer, Steven
Subject:3606 El Camino
Date:Friday, April 10, 2026 2:43:16 PM
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i
City Council and Staff,
I am writing to support the project at 3606 El Camino.
This property has sat vacant for so long and I think its great someone proposed a productive use for
this property. The current state of that property, which consists of a smog shop, a rusted chain-link
fence guarding a field of weeds, a construction dumpster, and an abandoned office building, is an
eye sore.
We are all aware of the risks involved if we fail to hit our RHNA numbers and approving a project of
this scale is a necessary move to ensure the City maintains its local zoning control and doesn't lose
those rights to the state again.
Another benefit of building here is that this location will support all of the people working along
Page Mill, at Stanford, or within the California Ave and Downtown districts. Putting housing density
where the jobs are will encourage residents to use alternative modes of transit and help reduce
traffic congestion.
Sincerely,
Beau Heidrich
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From:Joseph Doniach
To:Council, City
Cc:Barbara Powell
Subject:Agenda Item 8: 3606 El Camino Real
Date:Friday, April 10, 2026 3:57:11 PM
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on links.
Hello Palo Alto city council, my name is Joseph Doniach and I live in Greenmeadow.
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly apartments to our
community. I also support the city making additional transportation improvements around the project, such as
improved bike infrastructure, but I do not think those should impact the project.
Palo Alto residents have to accept the reality that the city needs more multi family housing. There simply isn’t the
space for single family housing, and the housing shortage is the primary reason for the insanely high cost of housing
in the SF Bay Area. If we want to have a community that includes regular people with regular jobs, we simply
MUST build more affordable housing and that necessarily will be multi family housing.
Thank you for supporting more homes in our community.
Joseph Doniach
From:Susan Kemp
To:Council, City
Subject:Agenda Item 8: [INSERT PUBLIC COMMENT TITLE]
Date:Friday, April 10, 2026 9:22:20 PM
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on links.
Hello Palo Alto city council, my name is [INSERT NAME] and I live in [INSERT NEIGHBORHOOD].
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly apartments to our
community. I also support the city making additional transportation improvements around the project, such as
improved bike infrastructure, but I do not think those should impact the project moving forward.
[CUSTOMIZE HERE WITH WHY YOU CARE OR DELETE].
Thank you for supporting more homes in our community,
[INSERT NAME]
Sent from my iPhone
From:Shane Pizzo
To:Council, City
Cc:City Mgr
Subject:Support for 3606 El Camino Real
Date:Saturday, April 11, 2026 7:28:44 AM
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i
Members of the Palo Alto City Council,
I am writing to voice my support for the apartment building development at 3606 El Camino
Real.
My family owns and manages commercial property in Palo Alto, so I drive by this site often.
Density in this location makes lots of sense to me, since it is both along El Camino and not
in the middle of a neighborhood. The location has good transit and biking options nearby at
California Avenue, bikeability to many commercial campuses, and good access to both 280
and 101. Altogether, it seems like a great location to add denser housing to Palo Alto.
Palo Alto, both as a rental market and housing market, has become largely unaffordable for
most people. That is in no small part due to a lack of new apartments that have been added
to the City housing supply over the past several decades. So it is great to see some projects
finally coming forward, which will hopefully increase the supply enough to make a dent in
the scarcity of housing in the area.
Please vote to approve the 3606 El Camino Real Project.
Thank you,
Shane Pizzo
Propervise, Inc.
CA DRE # 01964516
Cell - 408-891-1104
Email - Shane@propervise.com
www.propervise.com
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From:hebiux García-Bolio
To:Council, City
Subject:Agenda Item 8: [INSERT PUBLIC COMMENT TITLE]
Date:Saturday, April 11, 2026 8:49:38 AM
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i
Hello Palo Alto city council, my name is Hebe García- Bolio and I live in a section 8
Apartment - Sheridan Ave.
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly
apartments to our community. I also support the city making additional transportation
improvements around the project, such as improved bike infrastructure, but I do not think
those should impact the project moving forward.
I was homeless; found a despicable shelter and then a more humane: for women only.
Sometimes , people are not trained to treat the homeless with Dignity, Respect while we are
seeking our potential .
There are those that are trained and go beyond : with Joy, Dignity and Respect.
Kudos to them and you!
Thank you for supporting more homes in our community,
Hebe Garcia-Bolio
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From:Winter Dellenbach
To:Council, City
Subject:Item #8 3606 ECR
Date:Saturday, April 11, 2026 12:47:45 PM
To: City Council Members
From: Winter Dellenbach
Date: 4-11-26
RE: Item #8, 3606 El Camino Real
I realize this is a builders remedy project with a density bonus and therefore limitations apply to City
oversight. That said, here are some of my concerns about the 3606 El Camino Real mega-development. I
welcome gaining more affordable housing in our City, but this project isn’t reasonable in its immensity,
particulary given the cumulative impacts with the Creekside Inn proposed development just a few feet
away.
Displacement - I hope this annoys you even half as much as it annoys me
To really drive the nail into one's heel, the applicant’s proposal is to demolish 3 multifamily apartment
buildings (two and three story) on Kendall which will result in eviction of 38 households. Losing one’s
housing, as we know, is devastating, yet never is the word “displacement” mentioned in this packet.
If this landlord owns more than 10 units of housing, PAMC 9.68.060, Tenant Relocation Assistance
payments are required to be paid by owner to each household. Payments differ as to household size with a
range from about $8,000 to $20,000 in 2025, much more assistance than the owner waiving 1 months rent
as seems to be proposed in the packet.
Please confirm if the owner cumulatively owns if over 10 units in the 3 apartment buildings to be
demolished. If so, displaced tenants will be better positioned in seeking new housing than if PAMC
9.68.050 applies (10 or few units owned only get 1 months rent).
The Number of BMR Units
Is there anyway Council and require more than the paltry 37 BMR dwelling units (13% of 284 units with
density bonus = 37)? Without the bonus, there would be 42 BMR units (13% of the 321units actually
proposed = 42). This of course way under the 20% formerly required.
Unless there is a work around, this very large project will produce little affordability. If anyone thinks
Sacramento cares about affordable housing, they aren’t paying attention.
Please ensure that the BMR units will be distributed throughout the project, not isolated as a group in a sort
of low-income mini-ghetto.
It also seems there is an insufficient variety of unit sizes (studios, 1, 2 and 3 bedrooms). Council has a good
track record of ensuring a variety of sizes to allow for a variety of household sizes, finding that this is
necessary for a healthy community. Make sure this needed variety is guaranteed.
Bike Safety
Matadero Ave. on the proposed projects north side, is a safe route to school. It is 30-feet wide for only its
first 75-feet west of El Camino. It then suddenly narrows to just 18-feet as it continues into Barron Park.
The applicant proposes to widen the avenue by moving City utility vaults, poles, and removing a City street
tree.
Curvy Kendall Ave. varies some from 26 feet to a bit wider.
On both Matadero and Kendall, there is to be ingress/egress for 391cars and service vehicles from the
projects parking areas.
Given overflow street parking and ingress/egress issues, any shred of bike safety on Matadero will surely be
lost.
This project as proposed is not safe nor do I think it can effectively be made so.
Street Parking
What is developers plan to effectively mitigate traffic and overflow parking onto neighborhood streets and
its effect on Matadero’s safe route to school? There are 391 parking spaces proposed. Dollars to donuts
more than 70 households out of 321 will have 2 cars with the extra on unusually narrow adjacent streets.
Loading
It is vital, given the information above, that no off-site loading zone or refuse pick-up is permitted.
Providing sufficient onsite loading or refuse pickup should be a condition of approval.
The staff report/packet states:
The project includes one required loading space for developments with more than 50 units in
conformance with PAMC Chapter 18.24 objective standards.* However, the loading space is not
consistently shown across plan sheets. Therefore, a condition of approval has been added to
ensure that this off-site loading space is provided. Some plan sheets also show an on-street
loading area for both Matadero Avenue and Kendall Avenue. Given that: 1) the loading space on Kendall
Avenue is designed for refuse pickup.
*3 June 15, 2020, City Council Resolution 9894
(Palo Alto Local Transportation Impact Analysis Policy):
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=61625&dbid=0&repo=PaloAlto
School Route; 2) a loading space is already provided within the parking garage adjacent to the
lobby; 3) additional loading spaces are not required; and 4) the applicant does not have rights
to the City’s right-of-way, a condition of approval has been added requiring that the proposed
loading zone on Matadero Avenue be removed on the plans submitted for building permit.
Height of Project
Adjacent to this 85-foot development are a couple of 2 story apartment buildings on Kendal. Across this
curvy narrow street are some 1-story homes.
What is the plan to protect residents of these homes and 2-story apartment buildings from being
overwhelmed by the bulk and 85-foot height of the proposed development? And to protect their privacy?
Matadero Creek
I estimate the creek is 200 feet if measured from the inner western edge of the proposed development, not
300 feet as stated in the staff report/packet. Just saying.
From:Linnea
To:Council, City
Subject:Agenda Item 8: [INSERT PUBLIC COMMENT TITLE]
Date:Saturday, April 11, 2026 4:15:04 PM
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on links.
Hello Palo Alto city council, my name is Linnea Wickstrom and I live in Monroe Park.
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly apartments to our
community. I also support the city making additional transportation improvements around the project, such as
improved bike infrastructure, but I do not think those should impact the project moving forward.
Thank you for supporting more homes in our community,
Linnea Wickstrom
Sent from my iPhone
From:Amie Ashton
To:Council, City
Subject:Support for 3606 ECR!
Date:Sunday, April 12, 2026 12:08:29 AM
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Mayor Veenker and Honorable City Council,
I write in support of the project at 3606 El Camino Real. We need more modern and well-
equiped (AC, washing machines, energy efficient appliances, proper insulation, etc.) housing
units in our city at all income levels.
This project will bring hundreds of larger family-sized units close to local jobs, schools,
shopping, and restaurants. It will decrease our jobs/housing ratio, providing workers an
opportunity to live near their jobs, mode-shift out of cars, and reduce traffic, noise, and
climate/air quality impacts. This is a great project for our city in a a great place - the
innovative, Council-created El Camino Real Housing Focus Area!
Please encourage the applicant to provide adequate and ample bike parking. The #1
transportation-related issue I hear from renters is that there is a real lack of space to securely
park bikes, especially e-bikes. Further, bike rooms need to provide power outlets (many of
them) to charge e-bikes as more and more families and individuals move to a car-light
lifestyle. This is something our city should do everything to support!
Please approve this project without delay so we can bring these housing units online as soon as
possible.
Thank you,
Amie Ashton
From:Hayden Kantor
To:Council, City
Subject:Agenda Item 8: build more housing in Palo Alto!
Date:Sunday, April 12, 2026 1:02:18 PM
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Dear Palo Alto City Council,
I am a Palo Alto resident, who lives about half a mile from the proposed project, 3606 El
Camino Real. I urge you to approve it without any modifications or delay.
This stretch of El Camino is heavily blighted. It should be a vibrant neighborhood filled with
family-friendly apartments, walkable businesses (the new residents will be new customers),
bike infrastructure, and transit.
Regarding this project and also the proposed housing in the San Antonio area, I do not support
any height limits. I do not support the City Council or the Architectural or Planning
Committee meddling with the aesthetics.
I know you are hearing from residents who live nearby with lots of concerns or quibbles. Well,
I am a resident who also lives nearby who will be thrilled to see these apartments constructed.
We have to do do what is best for entire city. New housing will bring in new tax dollars,
new customers for businesses, and lower housing costs.
There is substantial evidence that the policy of IZ (Inclusionary Zoning) has not worked and
indeed functions as a tax of new housing, so I do not support maintaining these requirements
any further. Let's remove requirements and unleash new housing to make our community
more vibrant.
Thank you,
Hayden Kantor
2500 Columbia St Unit 107
Palo Alto
From:Tyler Osgood
To:Council, City
Subject:Agenda Item 8: Public Comment
Date:Sunday, April 12, 2026 1:37:51 PM
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Hello Palo Alto city council, my name is Tyler Osgood and I live on Hawthorne Ave. Please
vote to approve 3606 El Camino Real, which will bring much-needed family-friendly
apartments to our community. I also support the city making additional transportation
improvements around the project, such as improved bike infrastructure, but I do not think
those should impact the project moving forward.
Thank you for supporting more homes in our community!
Tyler Osgood
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From:Kirsten Flynn
To:Council, City
Subject:321 unit 3606 El Camino project
Date:Sunday, April 12, 2026 2:45:07 PM
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i
Honorable City Council Members,
I am writing as an involved life-time citizen of Palo Alto, one who has served the citizens of
this city as a PTA president, Mayors Green Ribbon Task Force member, and a member of the
Ventura Neighborhood CAC Committee. I currently live in the Ventura Neighborhood.
I am writing to support the PTC concerns on the safety of the project planned for 3606 El
Camino Real, and thus their concerns about the merger of these parcels.
My concern are entirely around the safe routes to school program. I also have volunteered on
the Safe Routes to School committee, and we MUST protect any hard won, incremental,
progress we have make to safeguard this system of streets. Matadero is a safe route to school
street. With the increased bicycle infrastructure on El Camino, this network becomes even
more important for ALL bicyclists, recreational, student and transportation.
Additionally I am fully supportive of increased density in my neighborhood, even as 7 stories
seems excessive. I look forward to welcoming new neighbors. This is because:
Even at 13% this apartment project would yield 40 affordable units.
The rest of the units would help our tremendous housing shortage, helping to balance
out our jobs/housing imbalance.
Because of the cost of housing in Palo Alto, we are becoming a geriatric city (with
myself as one example) This contributes to low enrollment in local schools.
Retail thrives on density, and this number of units will be a shot in the arm to local
retail. Our local businesses deserve to thrive- Celias, Di Sichuan, Indo, Thai Bistro,
even Green Mail, are doing a great job.
My preferences are that the City Council do what it can, within Builder’s remedy to:
Make the Safe Route To School safer, with a path past the project, for pedestrians,
bicyclists and cars.
Limit height to 6 stories.
Ask that the percentage of affordable units be increased to 20%
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Also, in the future, please consider ramming through some dense projects that affect Midtown,
Old Palo Alto, Professorville, and Downtown. The neighborhoods in South West Palo are not
the only locations ripe for re-development.
Best regards,
Kirsten Flynn
From:Alexandra Konings
To:Council, City
Subject:Agenda Item 8: please approve 3606 El Camino Real
Date:Sunday, April 12, 2026 3:32:02 PM
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Hello Palo Alto city council,
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly
apartments to our community. I also support the city making additional transportation
improvements around the project, such as improved bike infrastructure, but I do not think
those should impact the project moving forward. We should not be exposing the city to
legislation by rejection proposals that are protected by state law. Furthermore, having so many
new homes nearby will help the Cal Ave businesses continue to thrive.
Thank you
Alexandra Konings
Homeowner in College Terrace
From:Daniel Stein
To:Council, City
Subject:Agenda Item 8
Date:Sunday, April 12, 2026 4:10:57 PM
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i
Hello Palo Alto City Council, my name is Daniel.
Please vote to approve 3606 El Camino Real, which will bring much-needed family-friendly
apartments to our community. I also support the city making additional transportation
improvements around the project, such as improved bike infrastructure, but I do not think
those should impact the project moving forward.
Thank you for supporting more homes in our community,
Daniel Stein
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