HomeMy WebLinkAboutStaff Report 2604-6208CITY OF PALO ALTO
Policy & Services Committee
Special Meeting
Tuesday, April 14, 2026
6:00 PM
Agenda Item
3.Update on Citywide Development Impact Fee Nexus and Housing Feasibility Study. CEQA
Status: Exempt under CEQA Guidelines Section 15378. Late Packet Report Added, Staff
Presentation
Policy & Services Committee
Staff Report
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: April 14, 2026
Report #:2604-6208
TITLE
Update on Citywide Development Impact Fee Nexus and Housing Feasibility Study. CEQA
Status: Exempt under CEQA Guidelines Section 15378.
This report will be a late packet report published on March 9, 2026.
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Policy & Services Committee
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: April 14, 2026
Report #: 2603-6061
TITLE
Update on Citywide Development Impact Fee Nexus and Housing Feasibility Study. CEQA
Status: Exempt under CEQA Guidelines Section 15378.
RECOMMENDATION
Staff recommend the Committee receive an update on the subject effort and provide feedback
on potential 2050 residential and non-residential growth projections.
EXECUTIVE SUMMARY
Staff are conducting a comprehensive update of Palo Alto's development impact fees and
related in-lieu fees. In December 2025, City Council approved a professional services contract
with Keyser Marston Associates (KMA), with NBS Government Finance Group (NBS) as a
subconsultant, to prepare an AB 602-compliant nexus study and financial feasibility analysis.
This report provides a preliminary analysis of 2050 growth projections, which will serve as an
input for certain fee calculations related to transportation and fire safety, and provide a basis
for projecting fee revenues over time.
BACKGROUND
Development impact fees help ensure new development pays its fair share of the public
facilities needed to serve growth. Under California's Mitigation Fee Act (AB 1600), jurisdictions
may charge these fees when there is a reasonable relationship, or nexus, between the fee and
the type of development.
Assembly Bill 602, effective January 1, 2022, added requirements to adopt and update certain
impact fees at least every eight years. Palo Alto's Housing Element also requires timely updates
to certain housing-related fees and feasibility analyses.
To meet these state law and Housing Element requirements, and to create a consistent
citywide fee framework, the City Council approved a professional services contract in December
2025 to comprehensively update multiple impact and in-lieu fees. The work includes
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development forecasting, facility needs analysis, fee and revenue analysis, financial feasibility
testing, and implementation recommendations for administration, accounting, and reporting.
ANALYSIS
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number of existing residential units is based on the January 1, 2025 DOF report, increased by
0.3 percent to account for 2025 growth. The estimate of existing jobs in the City was based on
data from the 2022 Economic Census, adjusted to 2026. Non-residential development amounts
were estimated from the jobs data using employment density factors, with no assumed growth
in non-residential categories from 2022 to 2026 except in the office category, where 0.1
percent annual growth was applied.
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the likelihood that buildout will approach Plan Bay Area 2050's projections within the study
horizon.
Table 1: City of Palo Alto Residential Growth Projections Through 2050
Approximate Existing
Conditions (January 2026)
Low
Range
Plan Bay
Area 2050
Staff
Recommended
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planning horizon; 2,700 units associated with SB 79 development potential around existing
transit stations; and 2,400 units from the San Antonio Road corridor. This estimate is
considered conservative, reflecting real market constraints including elevated construction
costs, labor costs, and tight lending conditions that continue to compress development margins
and make it difficult for many builders to achieve the returns necessary to move projects
forward. That said, several factors could drive higher production over the horizon.
Development may occur outside of transit stations or housing focus areas; lower borrowing
costs or higher rents may stimulate greater activity; and local or state housing policies may
serve as additional catalysts. Conversely, if fewer units are produced, the city would collect less
fee revenue, while greater production would generate more revenue, though that revenue
would also correspond to increased demand for city services. Total development impact fee
revenue is demand-driven and fluctuates accordingly. Fees are required to be updated every
eight years, ensuring they remain calibrated to anticipated development levels and the
infrastructure planning needed to accommodate that growth.
Hotel/motel: the initially projected decline was revised upward because it was skewed
by a small number of recent projects that replaced hotels with housing; the revised
estimate reflects pipeline projects and development trends from 2018 to 2024.
Commercial: although some commercial space is being converted to residential use, the
initial projected decline was removed to reflect City efforts to strengthen retail along El
Camino Real and encourage ground-floor retail; commercial space is therefore projected
to remain at approximately 6.5 million square feet through 2050.
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Industrial: the initial estimate was reduced by 5 percent to reflect expected residential
development along San Antonio Road and Fabian Way, where some existing industrial
uses may transition.
Public facilities: the initial growth rate is retained to account for likely new public
facilities associated with the Cubberley Community Center project.
Job growth was then estimated using NBS employment density assumptions applied to the
projected increase in non-residential square footage by 2050.
Table 2: City of Palo Alto Existing Non-Residential Conditions and 2050 Growth Projections
Existing Conditions (estimated as
of January 2026)
Staff
Recommendation
Total Jobs 125,000 130,000
Total Hotel/Motel Rooms 2,500 2,750
Total Non-Residential Development 53,100,000 53,700,000
Total Square Feet of Commercial
Development 6,500,000 6,500,000
Total Square Feet of Office
Development 27,500,000 28,500,000
Total Square Feet of Medical
Development 8,000,000 8,000,000
Total Square Feet of Industrial
Development 10,500,000 10,000,000
Total Square Feet of Public Facilities
Development 600,000 700,000
Overall, the non-residential forecast reflects a relatively stable development picture, with net
growth of approximately 600,000 square feet and 5,000 jobs citywide by 2050. The modest
scale of this projection is intentional: it reflects the continued constraints on large-scale office
and commercial development in a largely built-out city, tempered by the policy adjustments
described above. Staff is comfortable that this estimate provides a reasonable basis for fee
calculations and revenue projections, and it will be revisited as part of the required eight-year
update cycle.
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Next Steps and Anticipated Schedule
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
APRIL 14, 2026
DEVELOPMENT IMPACT & IN-LIEU FEE STUDY
Policy & Services Committee Update
Julia Knight, Senior Program Manager
PaloAlto.gov
PRESENTATION OVERVIEW
Recommendation
Staff recommend the Committee receive an update on the subject effort
and provide feedback on potential 2050 residential and non-residential
growth projections.
Key Content
•Policy Context
•Project Scope and Timeline
•Fee Calculation Methodologies
•Preliminary Growth Projections
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POLICY CONTEXT
California's Mitigation Fee Act (established through AB 1600)
•Allows jurisdictions to charge impact fees to new development
•Requires a nexus study to justify impact fee amounts
AB 602
•Effective January 1, 2022
•Requires all impact fee nexus studies to be updated every 8 years
•Requires some fees to be charged on a per square foot basis*
Housing Element Program Requirements
•Evaluate and adopt updated parks, library, and community facilities
fees by September 2026
•Evaluate and update housing impact and in-lieu fees by January 2027
*Palo Alto made select fee calculations changes to comply in 2024
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TEAM & SCOPE
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Note: Utility-related and area-specific impact fees are not included in this study.
The team includes:
•NBS (nexus study lead)
•KMA (financial feasibility study lead)
Nexus and feasibility studies will be completed for the following fees:
Development Impact Fees In-Lieu Fees
•Park
•Community Center
•Library
•General Government Facility
•Citywide Transportation
•Public Safety Facility
•Housing
•Parkland Dedication
•Public Art
•Housing
May/June July/August September/
October
November/
December
January/
February
May/June July/AugustMarch/April
PROJECT TIMELINE
September/
October
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2025 2026
* Except for Citywide Transportation Fee; see slide 7 for details
TYPICAL IMPACT FEE CALCULATION METHODOLOGY
1.NBS to calculate existing level of service provided for most facilities
2.NBS and staff to identify and consider any existing deficiencies (or excess
capacity in facilities) or infrastructure
3.NBS and staff to identify any additional facilities and/or infrastructure
investments needed to continue to provide the existing level of service
through 2050
4.NBS to allocate facility costs in proportion to the impact of new
development by land use type to find maximum legally allowable fee
5.KMA to conduct financial feasibility study to determine the maximum fee
the market can support; consider implications for housing production
6.City to set fee at or below the maximum allowed fee based on financially
feasibility study
Note: In-Lieu fees will generally follow the same approach; citywide transportation impact fee and
public safety impact fee may be calculated using the methodology outlined on the next slide.
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OTHER METHODOLOGIES
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NBS may recommend using other methodologies for certain fees. For example, NBS
recommends using the planned facilities method to calculate the citywide
transportation impact fee.
1.Staff to identify the list capital improvement projects needed to serve projected
new development (based on preliminary growth projections)
2.Staff to calculate the cost of transportation facilities needed to serve new
development and NBS to apply a standard vehicle trips cost allocation method,
relying on ITE data factors for trips and average trip length (if applicable), to set
the maximum legally allowable fee
3.KMA to provide the City with a summary of financial feasibility considerations
4.City to set fee at or below the maximum legally allowable fee based on these
considerations
Transportation Impact Fee Timeline
The City has until 2030 to update this fee under AB 602, but staff is targeting a mid-
2027 update to support a streamlined and coordinated fee update effort citywide.
RESIDENTIAL GROWTH PROJECTIONS
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Projections will
inform
transportation
impact fee
calculations and
serve as the basis
for fee revenue
projections and
facilities planning.
Notes: The estimated 6,200 new housing units includes 2,100 units from pipeline project
conversions; 1,600 ADUs citywide over the planning horizon; 2,700 units associated with SB
79 development potential around existing transit stations; and 2,400 units from the San
Antonio Road corridor. Total population may vary based on household size and/or residential
vacancy rate changes.
NON-RESIDENTIAL GROWTH PROJECTIONS
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Projections will
inform
transportation
impact fee
calculations and
serve as the basis
for fee revenue
projections and
facilities planning.
JULIA KNIGHT
Senior Program Manager
julia.knight@paloalto.gov
650-838-2839