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HomeMy WebLinkAbout2026-04-20 City Council Agenda PacketCITY COUNCIL Regular Meeting Monday, April 20, 2026 Council Chambers & Hybrid 5:30 PM Amended Agenda Amended agenda items appear below in RED   Palo Alto City Council meetings will be held as “hybrid” meetings with the option to attend by teleconference or in person. Information on how the public may observe and participate in the meeting is located at the end of the agenda. The meeting will be broadcast on Cable TV Channel 26, live on YouTube https://www.youtube.com/c/cityofpaloalto, and streamed to Midpen Media Center https://midpenmedia.org. VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/362027238) Meeting ID: 362 027 238 Phone:1(669)900-6833   PUBLIC COMMENTS General Public Comment for items not on the agenda will be accepted in person for up to three minutes or an amount of time determined by the Chair. General public comment will be heard for 30 minutes. Additional public comments, if any, will be heard at the end of the agenda. Public comments for agendized items will be accepted both in person and via Zoom for up to three minutes or an amount of time determined by the Chair. Requests to speak will be taken until 5 minutes after the staff’s presentation or as determined by the Chair. Written public comments can be submitted in advance to city.council@PaloAlto.gov and will be provided to the Council and available for inspection on the City’s website. Please clearly indicate which agenda item you are referencing in your subject line. Multiple individuals who wish to speak on the same item may designate a spokesperson. Spokespersons must be representing five or more verified individuals who are present either in person or via zoom. Spokespeople will be allowed up to 10 minutes, at the discretion of the presiding officer. Speaking time may be reduced if the presiding officer reduces the speaking time for individual speakers. PowerPoints, videos, or other media to be presented during public comment are accepted only by email to city.clerk@PaloAlto.gov at least 24 hours prior to the meeting. Once received, the Clerk will have them shared at public comment for the specified item. To uphold strong cybersecurity management practices, USB’s or other physical electronic storage devices are not accepted. Signs and symbolic materials less than 2 feet by 3 feet are permitted provided that: (1) sticks, posts, poles or similar/other type of handle objects are strictly prohibited; (2) the items do not create a facility, fire, or safety hazard; and (3) persons with such items remain seated when displaying them and must not raise the items above shoulder level, obstruct the view or passage of other attendees, or otherwise disturb the business of the meeting. TIME ESTIMATES Listed times are estimates only and are subject to change at any time, including while the meeting is in progress. The Council reserves the right to use more or less time on any item, to change the order of items and/or to continue items to another meeting. Particular items may be heard before or after the time estimated on the agenda. This may occur in order to best manage the time at a meeting or to adapt to the participation of the public.  1 April 20, 2026 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas. CALL TO ORDER   SPECIAL ORDERS OF THE DAY (5:30 - 5:45 PM)   1.​Proclamation Recognizing Earth Day and the Palo Alto Youth Climate Advisory Board​ 2.Proclamation Recognizing National Crime Victims' Rights Week April 19-25, 2026 AGENDA CHANGES, ADDITIONS AND DELETIONS   PUBLIC COMMENT (5:45 - 6:15 PM) Members of the public may speak in-person ONLY to any item NOT on the agenda. 1-3 minutes depending on number of speakers. Public Comment is limited to 30 minutes. Additional public comments, if any, will be heard at the end of the agenda. COUNCIL MEMBER QUESTIONS, COMMENTS, ANNOUNCEMENTS (6:15 - 6:25 PM) Members of the public may not speak to the item(s).   STUDY SESSION (Item 3: 6:25 - 7:25 PM, Item 4: 7:25 - 8:25 PM)   3.Discussion of the Draft 2026-2030 Santa Clara County Community Plan to End Homelessness; CEQA Status—Not a project.   4.910 Webster Street [26PLN-00026]. Request for Council Prescreening to Rezone the Subject Property from RM-20 to Planned Community/Planned Home Zoning and to Allow Construction of 70 Residential Units in a Seven-Story Structure. CEQA Status: Not a Project.   CONSENT CALENDAR (8:25 - 8:30 PM) Items will be voted in one motion unless removed from the calendar by three Council Members.   5.Approval of Minutes from April 6, 2026 Meeting 6.Adopt a Resolution Authorizing the Director of Planning and Development Services to Make Minor Modifications to the 2023-2031 Housing Element Site Inventory. CEQA Status: The City Council adopted a Revised Addendum to the Comprehensive Plan Final Environmental Impact Report on December 18, 2023, that, in conjunction with the Comprehensive Plan Final EIR, fully analyzes the impacts of the 6th Cycle Housing Element, including minor modifications to the site inventory. Supplemental Report Added  2 April 20, 2026 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas. 7.Approval of Amendment Number 1 to Contract C23187554 with Vox Network Solutions to Increase Compensation by $212,819 and to Extend the Term to June 30, 2027, for Maintenance of the City’s Enterprise Phone System; CEQA Status – exempt under section 15061(b)(3). 8.FIRST READ: Adopt an Entertainment Zone Ordinance to Establish an Entertainment Zone on California Avenue as Recommended by the Economic Development Ad Hoc Committee; CEQA status – Categorically Exempt. 9.Approval of Contract Amendment No. 3 to Contract S25190354 with Larratt Brothers Plumbing Inc. in the Amount of $950,000, for a Revised Total Not to Exceed $1,445,000 and to Extend the Contract Term for One Additional Year ending July 21, 2027, for the Residential Emergency Water Heater Replacement Pilot Program Within Electrification Programs; CEQA Status – Not a Project. 10.4075 El Camino Way [23PLN-00202]: Recommendation to Decline Adoption on Second Reading of an Ordinance Adopting an Amendment to a Planned Community Ordinance (PC-5116) to Allow for Modifications to an Existing 121-Unit Assisted Living and Memory Care Facility. First Reading Adoption was on March 16, 2026. CEQA Status: Exempt from the Provisions of the California Environmental Quality Act (CEQA) in Accordance with CEQA Guidelines Section 15301 (Modifications to Existing Facilities). Supplemental Report Added AA1.Amend the FY 2026 Budget Appropriation for the Capital Improvement Fund to Establish the Embarcadero Road Improvement Project, Phase 1, and Authorize the City Manager or Their Designee to Award a Construction Contract with a Qualified Contractor for the Embarcadero Road Improvement Project, Phase 1; CEQA Status – Exempt under CEQA Guidelines Section 15301(c) New Item Added CITY MANAGER COMMENTS (8:30 - 8:40 PM)   BREAK (15 MINUTES) ACTION ITEMS (Item 11: 8:55 - 10:00 PM; Item 12: 10:00 - 10:30 PM) Include: Report of Committees/Commissions, Ordinances and Resolutions, Public Hearings, Report of Officials, Unfinished Business and Council Matters.   11.Quasi-Judicial: Adoption of a Resolution Documenting the City Council’s Consideration and Decision on an Appeal of the Chief Building Official’s Order to Demolish the Buildings Located at 531 Stanford Avenue. 12.Adoption of Recommendations by the Policy & Services Committee Implementing Changes to Meeting Procedures Related to Teleconferencing, Remote Public Participation, Translation and Interpretation Assistance, and Expanded Public Outreach;  3 April 20, 2026 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas. CEQA Status – Not a Project. ADJOURNMENT INFORMATION REPORTS Information reports are provided for informational purposes only to the Council and the public but are not listed for action or discussion during this meeting’s agenda.   A.Monthly Investment Report - March 2026 (Unaudited) AA2.Informational Update on Stanford Palo Alto Community Playing Fields (Mayfield) PFAS Testing Results New Item Added OTHER INFORMATION Standing Committee Meetings this week Finance Committee April 21, 2026 City Schools Liaison Committee April 23, 2026 Public Comment Letters Schedule of Meetings   AMENDED AGENDA ITEMS   6.Adopt a Resolution Authorizing the Director of Planning and Development Services to Make Minor Modifications to the 2023-2031 Housing Element Site Inventory. CEQA Status: The City Council adopted a Revised Addendum to the Comprehensive Plan Final Environmental Impact Report on December 18, 2023, that, in conjunction with the Comprehensive Plan Final EIR, fully analyzes the impacts of the 6th Cycle Housing Element, including minor modifications to the site inventory. Supplemental Report Added   10.4075 El Camino Way [23PLN-00202]: Recommendation to Decline Adoption on Second Reading of an Ordinance Adopting an Amendment to a Planned Community Ordinance (PC-5116) to Allow for Modifications to an Existing 121-Unit Assisted Living and Memory Care Facility. First Reading Adoption was on March 16, 2026. CEQA Status: Exempt from the Provisions of the California Environmental Quality Act (CEQA) in Accordance with CEQA Guidelines Section 15301 (Modifications to Existing Facilities). Supplemental  4 April 20, 2026 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas. Report Added   AA1.Amend the FY 2026 Budget Appropriation for the Capital Improvement Fund to Establish the Embarcadero Road Improvement Project, Phase 1, and Authorize the City Manager or Their Designee to Award a Construction Contract with a Qualified Contractor for the Embarcadero Road Improvement Project, Phase 1; CEQA Status – Exempt under CEQA Guidelines Section 15301(c) New Item Added   AA2.Informational Update on Stanford Palo Alto Community Playing Fields (Mayfield) PFAS Testing Results New Item Added   PUBLIC COMMENT INSTRUCTIONS Members of the Public may provide public comments to teleconference meetings via email, teleconference, or by phone. 1.Written public comments may be submitted by email to city.council@PaloAlto.gov. 2.For in person public comments please complete a speaker request card located on the table at the entrance to the Council Chambers and deliver it to the Clerk prior to discussion of the item. 3.Spoken public comments for agendized items using a computer or smart phone will be accepted through the teleconference meeting. To address the Council, click on the link below to access a Zoom-based meeting. Please read the following instructions carefully. ◦You may download the Zoom client or connect to the meeting in- browser. If using your browser, make sure you are using a current, up-to-date browser: Chrome 30 , Firefox 27 , Microsoft Edge 12 , Safari 7 . Certain functionality may be disabled in older browsers including Internet Explorer. Or download the Zoom application onto your smart phone from the Apple App Store or Google Play Store and enter in the Meeting ID below. ◦You may be asked to enter an email address and name. We request that you identify yourself by name as this will be visible online and will be used to notify you that it is your turn to speak. ◦When you wish to speak on an Agenda Item, click on “raise hand.” The Clerk will activate and unmute speakers in turn. Speakers will be notified shortly before they are called to speak. ◦When called, please limit your remarks to the time limit allotted. A timer will be shown on the computer to help keep track of your comments. 4.Spoken public comments for agendized items using a phone use the telephone number listed below. When you wish to speak on an agenda item hit *9 on your phone so we know that you wish to speak. You will be asked to provide your first and last name before addressing the Council. You will be advised how long you have to speak. When called please limit your remarks to the agenda item and time limit allotted.  5 April 20, 2026 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas. CLICK HERE TO JOIN Meeting ID: 362-027-238 Phone: 1-669-900-6833 Americans with Disability Act (ADA) It is the policy of the City of Palo Alto to offer its public programs, services and meetings in a manner that is readily accessible to all. Persons with disabilities who require materials in an appropriate alternative format or who require auxiliary aids to access City meetings, programs, or services may contact the City’s ADA Coordinator at (650) 329-2550 (voice) or by emailing ada@PaloAlto.gov. Requests for assistance or accommodations must be submitted at least 24 hours in advance of the meeting, program, or service. California Government Code §84308, commonly referred to as the "Levine Act," prohibits an elected official of a local government agency from participating in a proceeding involving a license, permit, or other entitlement for use if the official received a campaign contribution exceeding $500 from a party or participant, including their agents, to the proceeding within the last 12 months. A “license, permit, or other entitlement for use” includes most land use and planning approvals and the approval of contracts that are not subject to lowest responsible bid procedures and have a value over $50,000. A “party” is a person who files an application for, or is the subject of, a proceeding involving a license, permit, or other entitlement for use. A “participant” is a person who actively supports or opposes a particular decision in a proceeding involving a license, permit, or other entitlement for use, and has a financial interest in the decision. The Levine Act incorporates the definition of “financial interest” in the Political Reform Act, which encompasses interests in business entities, real property, sources of income, sources of gifts, and personal finances that may be affected by the Council’s actions. If you qualify as a “party” or “participant” to a proceeding, and you have made a campaign contribution to a Council Member exceeding $500 made within the last 12 months, you must disclose the campaign contribution before making your comments.  6 April 20, 2026 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas. City Council Staff Report Report Type: SPECIAL ORDERS OF THE DAY Lead Department: City Clerk Meeting Date: April 20, 2026 Report #:2604-6196 TITLE Proclamation Recognizing Earth Day and the Palo Alto Youth Climate Advisory Board ATTACHMENTS Attachment A: Earth Day and Palo Alto Youth Climate Advisory Board APPROVED BY: Mahealani Ah Yun, City Clerk Item 1 Item 1 Staff Report        Item 1: Staff Report Pg. 1  Packet Pg. 7 of 489  Recognizing Earth Day and the Palo Alto Youth Climate Advisory Board WHEREAS, anthropogenic climate change is a threat to the wellbeing of communities around the world, including Palo Alto; and WHEREAS, the City of Palo Alto is committed to reducing greenhouse gas emissions to mitigate climate change, to protecting and enhancing the natural environment, and to increasing livability in Palo Alto for residents through climate adaptation; and WHEREAS, youth are both the demographic most affected by the impacts of climate change and uniquely positioned to educate their peers and motivate action for a more sustainable community; and WHEREAS, the inaugural Youth Climate Advisory Board convened in September 2024 to address issues of sustainability and climate action relevant to Palo Alto youth and to support the City in implementing the Sustainability and Climate Action Plan, and WHEREAS, each year, “Earth Day” is celebrated by people globally, recognizing the value of the natural environments that sustain us and the importance of mitigating climate change, and WHEREAS, the ultimate success of Palo Alto is strongly correlated to the care of the natural resources that sustain us; and WHEREAS, on April 22nd, 2026, the City of Palo Alto is observing Earth Day. NOW, THEREFORE I, Vicki Veenker, Mayor of the City of Palo Alto, do hereby proclaim April 22nd as Palo Alto Earth Day, commend the Youth Climate Advisory Board for their leadership in promoting climate action and sustainability, and urge all residents to acknowledge the importance of climate action and sustainability, to care for the natural environment, to support our City’s multi-faceted sustainability and climate action programs, and to take action to reduce greenhouse gas emissions. Presented: April 20, 2026 ______________________________ Vicki Veenker Mayor Proclamation Item 1 Attachment A - Earth Day and Palo Alto Youth Climate Advisory Board​        Item 1: Staff Report Pg. 2  Packet Pg. 8 of 489  9 7 9 2 City Council Staff Report Report Type: SPECIAL ORDERS OF THE DAY Lead Department: City Clerk Meeting Date: April 20, 2026 Report #:2604-6231 TITLE Proclamation Recognizing National Crime Victims' Rights Week April 19-25, 2026 ATTACHMENTS Attachment A: National Crime Victims’ Rights Week APPROVED BY: Mahealani Ah Yun, City Clerk Item 2 Item 2 Staff Report        Item 2: Staff Report Pg. 1  Packet Pg. 9 of 489  NATIONAL CRIME VICTIMS’ RIGHTS WEEK April 19-25, 2026 WHEREAS, violent crime touches too many people in Palo Alto, as it does in all parts of our county; and WHEREAS, since 1981, National Crime Victims’ Rights Week has served as a time to honor the strength and resilience of crime victims, elevate their voices, and reaffirm our commitment to ensuring justice, healing, and support for all those impacted by crime; and WHEREAS, crime victims and their families often face emotional, physical, and financial hardships, and it is essential that they are treated with dignity, respect, and compassion while being informed of, and able to exercise, their rights; and WHEREAS, the Santa Clara County District Attorney’s Office Victim Services Unit (VSU) is the designated Victim Witness Assistance Program pursuant to California Penal Code §13835, providing comprehensive, trauma- informed, and client-centered services to victims of all types of crime, regardless of whether charges are filed; and WHEREAS, the VSU is staffed by specially trained professionals who assist victims in understanding and exercising their rights throughout and beyond the criminal justice process, including providing crisis intervention, emergency assistance, court support, resource referrals, and assistance with compensation and restitution; and WHEREAS, in the past year, the VSU has demonstrated its commitment to the community by providing over 79,000 services to more than 7,350 crime victims throughout Santa Clara County; and WHEREAS, the VSU Claims Unit processed over 2,400 California Victim Compensation Board applications in 2025, securing $1,896,466 in financial assistance to help victims, including those in Palo Alto, recover from crime- related expenses; and WHEREAS, in 2025, the District Attorney’s Office expanded access to the VSU in North County by offering in- person victim advocate services at the Palo Alto branch of the District Attorney’s Office, increasing accessibility for local residents; and WHEREAS, raising awareness of victims’ rights and available services strengthens our community’s ability to respond to and support those impacted by crime, ensuring that no victim feels alone on their path toward healing and justice. NOW, THEREFORE I, Vicki Veenker, Mayor of the City of Palo Alto on behalf of the entire City Council, do hereby proclaim April 19–25, 2026, as National Crime Victims’ Rights Week in the City of Palo Alto, and encourage all residents to recognize the importance of victims’ rights, support those impacted by crime, and promote access to services that foster safety, healing, and justice for all. Presented: April 20, 2026 _____________________________ Vicki Veenker Mayor Proclamation Item 2 Attachment A - National Crime Victims' Rights Week        Item 2: Staff Report Pg. 2  Packet Pg. 10 of 489  City Council Staff Report From: City Manager Report Type: STUDY SESSION Lead Department: City Manager Meeting Date: April 20, 2026 Report #:2601-5875 TITLE Discussion of the Draft 2026-2030 Santa Clara County Community Plan to End Homelessness; CEQA Status—Not a project. RECOMMENDATION Staff recommends that City Council discuss and provide feedback to County representatives on the Draft 2026-2030 Santa Clara County Community Plan to End Homelessness. EXECUTIVE SUMMARY This transmits and provides a forum for Santa Clara County (County) staff to discuss and receive feedback from Council on the Draft 2026-2030 Santa Clara County Community Plan to End Homelessness. County staff will be at the April 20, 2026 Council meeting to present information and discuss the Draft Plan with the Council. Ultimately, once the County has completed outreach and finalized the Draft Plan, staff and the County anticipate the final plan to come back to the Council for review and endorsement. For the past five years, the City has aligned its work relating to homelessness and stability to the County’s 2020-2025 Community Plan to End Homelessness goals addressing the root causes of homelessness, improving the quality of life for unsheltered individuals, and creating healthy neighborhoods for all, and expanding homelessness prevention and housing programs to meet demand. The 2020-2025 Plan achieved its goal of 20,830 people housed and made significant progress on a variety of fronts, including a 19 percent decrease in new households becoming homeless.1 The new proposed draft 2026-2030 Plan contains focus areas to reduce inflow into homelessness, help people to get and stay housed, strengthen access to care and services for people experiencing unsheltered homelessness, and center people with lived experience to lead and transform the homeless system. Similar to the 2020-2025 Plan, much of current City policy and work relating to homelessness and housing stability also aligns with the new draft Plan. 1 2020-2025 Community Plan to End Homelessness Final Progress Report, communityplan-2025-final-progress- report. Item 3 Item 3 Staff Report        Item 3: Staff Report Pg. 1  Packet Pg. 11 of 489  This staff report summarizes County data related to homelessness among people affiliated with Palo Alto to help provide a shared fact base and support Council discussion and feedback on the new draft Plan. BACKGROUND 3 Over the Plan’s five-year time period, the City of Palo Alto engaged in a variety of efforts supporting the Plan’s strategies,4 including: 5 20,830 people housed (goal was 20,000), consisting of 47 percent chronically homeless and 26 percent families with children, 27,037 people placed in temporary housing and shelter, 38,060 people received homelessness prevention assistance, with 93 percent of families remaining stably housed while receiving services, 19 percent decrease in new households becoming homeless, 82 percent increase in temporary housing and shelter capacity, consisting of 1,533 shelter units, 1,190 interim housing units, 365 other transitional housing programs, and 332 safe parking spaces, and 56 deeply affordable and supportive housing developments equaling more than 6,500 homes open, under construction, or in the pipeline. 3 City Council Staff Report, August 8, 2021, https://www.cityofpaloalto.org/files/assets/public/v/1/agendas- minutes-reports/reports/city-manager-reports-cmrs/year-archive/2021/id-13453.pdf. 4 City Council Staff Report, February 10, 2025, https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=6751&meetingTemplateType=2&comp iledMeetingDocumentId=13091 . 5 City Council Staff Presentation, August 25, 2025, https://cityofpaloalto.primegov.com/api/compilemeetingattachmenthistory/historyattachment/?historyId=13976 d90-1d8c-42c7-988f-e84d17a90ad0. Item 3 Item 3 Staff Report        Item 3: Staff Report Pg. 2  Packet Pg. 12 of 489  Going forward, the new draft Plan9 was built over several months of stakeholder engagement and in consultation with community members, service providers, people with lived experience, and staff from different jurisdictions within the County. The draft Plan identifies the following four focus areas, each accompanied by three strategies, emphasizing capacity and access, service delivery, and system coordination: Focus Area 1 — Prevent people from becoming homeless o Strategy A – Expand programs and investments to prevent people from becoming homeless o Strategy B – Ensure services are effective to prevent people from becoming homeless o Strategy C – Enhance coordination across systems to prevent people from becoming homeless Focus Area 2 — Continue to house people and support them in retaining their housing o Strategy A – Increase and maintain a continuum of housing options that meets the need o Strategy B – Increase consistency, diversity, and quality of housing and services for people accessing the housing continuum o Strategy C – Improve system coordination throughout the housing continuum Focus Area 3 — Strengthen access to care and services for people experiencing unsheltered homelessness o Strategy A – Build capacity and expand access to trusted, culturally responsive, and coordinated services and resources throughout Santa Clara County o Strategy B – Increase consistency, variety, and quality of outreach, basic, and essential needs services o Strategy C – Invest in approaches that improve outcomes and reduce harm for people living unsheltered and the community at-large Focus Area 4 — Center and invest in people with lived experience to lead and transform the homeless system o Strategy A – Expand the representation of people with lived experience in leadership roles and decision-making bodies o Strategy B – Build leadership capacity and advancement pathways for people with lived experience o Strategy C – Equip homeless system partners to effectively partner with people with lived experience 9 See Attachment A: Santa Clara County Draft Plan to End Homelessness, https://url.usb.m.mimecastprotect.com/s/KAYACoABY2cDNOnGH1fzSpUmsx?domain=osh.santaclaracounty.gov Item 3 Item 3 Staff Report        Item 3: Staff Report Pg. 3  Packet Pg. 13 of 489  ANALYSIS To best discuss the new draft Plan, it’s helpful to understand the current flow of Palo Alto- affiliated people11 into and out of homelessness, as well as how the City’s current efforts align with the draft Plan’s focus areas and strategies. The following summarizes County data related to homelessness among people affiliated with Palo Alto, drawing on the January 2025 Point-in-Time (PIT) Count12 and the Santa Clara County Office of Supportive Housing (OSH) Homeless Management Information System (HMIS) data for Calendar Year (CY) 202513. The data reflect two core realities: The January 2025 PIT count identified 418 individuals experiencing homelessness in Palo Alto, including 399 individuals (95%) who were unsheltered. People who are sheltered and experiencing homelessness include those in emergency shelters, transitional housing, or safe havens. Those who are unsheltered are living in places not designed for habitation, such as outdoors, vehicles, streets, parks or abandoned buildings. Palo Alto’s unsheltered proportion is higher than the countywide average, which makes sense given system constraints previously identified in the City’s Housing and Unhoused Services Gap Analysis (e.g., limited interim shelter capacity and housing supply). In partnership with Santa Clara County and a network of nonprofit and healthcare providers, Palo Alto supports outreach, stabilization, interim pathways, housing problem-solving, housing navigation, and supportive services. OSH/HMIS data indicates substantial service activity across programs during CY2025, reflecting both ongoing need and significant partner work. Key CY2025 HMIS data findings include: Coordinated Entry Inflow: 297 Palo Alto–affiliated households completed coordinated entry assessments, a consistent, community-wide intake process used to match people to appropriate resources14. 11 For purposes of this staff report, “Palo Alto–affiliated” refers to households identified in OSH/HMIS jurisdiction- level reporting as having a connection to Palo Alto (commonly based on information collected during system engagement, such as self-reported connection and/or service location). 12 County of Santa Clara, Office of Supportive Housing (OSH), “Point-in-Time Count,” https://osh.santaclaracounty.gov/data-and-reports/point-time-count, accessed March 6, 2026. 13 Santa Clara County Office of Supportive Housing (OSH), HMIS jurisdiction-level reporting for Palo Alto (Calendar Year 2025). Source file provided to the City, see Attachment B: Santa Clara County Office of Supportive Housing – Calendar Year 2025 Report (Palo Alto). 14 County of Santa Clara, Office of Supportive Housing (OSH), “Glossary of terms,” https://osh.santaclaracounty.gov/glossary-terms , accessed March 6, 2026. Item 3 Item 3 Staff Report        Item 3: Staff Report Pg. 4  Packet Pg. 14 of 489  Housing Requests and Placements: 154 Palo Alto–affiliated households requested housing assistance, and 71 households were placed into permanent housing. Placements occur through the countywide system and may be located outside Palo Alto. Service Utilization: Demand remains high across outreach, interim/shelter pathways, housing programs, and service-only supports. Please note, PIT data are reported as individuals (persons), while coordinated entry and HMIS measures are often reported as households; these measures are not directly comparable. In HMIS reporting, households may also appear in multiple categories19 based on service needs and enrollment during the year20. System Inflow and Housing Outcomes (CY2025) Santa Clara County’s Office of Supportive Housing administers the countywide homelessness response system, including coordinated entry, housing placement, and service tracking through the Homeless Management Information System (HMIS). Households experiencing homelessness are assessed using the Vulnerability Index–Service Prioritization Decision Assistance Tool (VI-SPDAT), which helps prioritize households for available housing resources. HMIS data reflects participating providers and programs; some services may be underrepresented if they are not entered in HMIS. The following information is derived from HMIS and reflects system activity across CY202521. Coordinated Entry inflow provides an indicator of the scale of household need entering (or re- entering) the homelessness response system. In CY2025, 154 Palo Alto–affiliated households completed first time coordinated entry assessments, compared to 126 in CY2024. With a high unsheltered rate, it is important for Palo Alto to focus on prevention (e.g., helping people to stay housed) to reduce the overall inflow, problem-solving through interim pathways (e.g., identifying and connecting to appropriate shelter or resources) to decrease the percent who are unsheltered, and placement (i.e., into permanent housing) to improve outflow. Housing requests and placements reflect movement through the County’s coordinated housing system. In CY2025, 154 Palo Alto–affiliated households requested housing assistance and 71 households were placed into permanent housing (countywide: 3,858 requests and 2,012 placements). Because placements occur through the countywide system, housing may be located outside Palo Alto; destination geography is not consistently available in the dataset 5The "breakdown of services" refers to the detailed, client-level tracking of specific assistance provided to individuals or households experiencing or at risk of homelessness. This data is categorized to track service use patterns, measure program effectiveness, and ensure that federal, state, and local funding is accurately reported. Uplift is a specific services related to bus passes. 21 County of Santa Clara, Office of Supportive Housing (OSH), “Glossary of terms,” accessed March 6, 2026. Item 3 Item 3 Staff Report        Item 3: Staff Report Pg. 5  Packet Pg. 15 of 489  used for this summary25. For those experiencing homelessness, placement outcomes are one of the primary pathways to reducing unsheltered exposure and associated harms. Additionally, increasing the pace of stabilization and housing pathways supports improved conditions in public-facing areas over time. Program Participation — Palo Alto–Affiliated Households (CY2025) 26. Permanent Supportive Housing27: 219 households enrolled (214 housed) Rapid Rehousing28: 74 enrolled (57 housed) Emergency Housing Voucher Program: 26 enrolled (26 housed) Emergency Shelter29: 272 served Transitional Housing30: 16 served Safe Parking: 72 served Street Outreach: 187 served Housing Problem Solving31: 203 served Services Only (incl. UPLIFT)32: 563 served Homelessness Prevention: 29 served 25 Santa Clara County Office of Supportive Housing (OSH), HMIS jurisdiction-level reporting for Palo Alto (Calendar Year 2025). Source file provided to the City and attached to this staff report packet: City_of_Palo_Alto_Report_OSH_CY2025.xlsx. 26 Santa Clara County Office of Supportive Housing (OSH), HMIS jurisdiction-level reporting for Palo Alto (Calendar Year 2025). Source file provided to the City and attached to this staff report packet: City_of_Palo_Alto_Report_OSH_CY2025.xlsx. 27 Housing target towards chronically homeless individuals and families, providing a rental subsidy, intensive case management, and health care. https://osh.santaclaracounty.gov/glossary-terms 28 An intervention to help individuals or families quickly exit homelessness, consisting of identifying housing, providing a modest/declining/temporary rent subsidy, and time-limited case management. 29 Temporary shelter provided for a specific time period only (e.g., 90 days). 30 Temporary supportive housing, typically provided for a limited time (e.g., 2 weeks to 2 years). 31 A Santa Clara County program to help households identify choices and solutions to end their housing crisis (i.e., prevent homelessness or achieve housing stability). https://files.santaclaracounty.gov/exjcpb1571/migrated/SCC%20CoC%20- %20Housing%20Problem%20Solving%20Guidelines%20062821.pdf 32The Office of Supportive Housing defines support services as targeted, often individualized, assistance designed to help people experiencing homelessness or housing instability obtain permanent housing, retain their tenancy, and improve their stability. These services encompass housing navigation, case management, health services, and life skills training tailored to specific needs. UPLIFT refers to a service that provides bus passes to unhoused individuals. Item 3 Item 3 Staff Report        Item 3: Staff Report Pg. 6  Packet Pg. 16 of 489  These numbers, especially the high “services-only” and outreach counts, may suggest a sustained need for engagement and stabilization while households navigate limited interim and permanent housing supply. Another takeaway from this data, is that the breadth of outreach and supportive service participation reflects ongoing harm-reduction, health connection, and crisis-prevention work that supports safer outcomes for vulnerable residents. Additionally, consistent outreach and pathways to housing stability help address impacts in high-use public areas by connecting people to services and reducing the duration/intensity of unsheltered episodes. Past and Current City Efforts and Alignment with Draft Plan Focus Area 1 – Prevent people from becoming homeless Effort Description 41. Requirement to offer a 1-year lease at lease renewal for covered units (PAMC Section 9.68.030) Just cause eviction protections that are applicable to more units than protections required by State law (PAMC Section 9.68.040) Tenant Relocation Assistance for no-fault evictions for covered units at rates equal to or likely exceeding assistance levels required by State law (PAMC Section 9.68.050; PAMC Section 9.68.060) Renter’s remedies if there is noncompliance with housing rental housing stabilization requirements (PAMC Section 9.68.080) 41 https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-66860 Item 3 Item 3 Staff Report        Item 3: Staff Report Pg. 7  Packet Pg. 17 of 489  Focus Area 2 – Continue to house people and support them in retaining their housing Housing Services Awarded Alta Housing $87,756 (HSRAP) for enhanced housing services including youth enrichment, community-building, and economic stability services to low-income youth and families residing in Alta Housing communities. Awarded Silicon Valley Independent Living Center $20,067 (CDBG) to provide case management services to low-income individuals with disabilities to secure affordable and accessible housing. Awarded LifeMoves $39,154 (CDBG) to provide housing navigation, benefits counseling and broader case management services to clients at the Opportunity Center. Food security Awarded $10,000 (Emerging Needs grant) to Alta Housing to expand its food security initiative. Below Market Rate Housing Program Contracted with Alta Housing to administer the City’s Below Market Rate (BMR) program designed to expand access to affordable ownership and rental housing by requiring or facilitating the creation of deed-restricted units for low- and moderate-income households. Focus Area 3 – Strengthen access to care and services for people experiencing unsheltered homelessness Overnight warming location (OWL) Awarded $113,166 (HSRAP) to Heart and Home Collaborative for Overnight Warming location for unhoused individuals, and $10,000 (Emerging Needs grant) to lengthen the opening dates of the cold weather shelter season. Outreach services to RV dwellers Awarded $70,360.00 to Karat School Project for outreach services to the RV Dweller community in Palo Alto. Food security Awarded $94,174.00 to LifeMoves to reduce food insecurity for unhoused individuals by providing breakfast and lunch Monday-Friday. Outreach & street medicine Awarded $241,422 (HSRAP) to Peninsula Healthcare Connections for outreach service, mental health support and street medicine for low income and unhoused individuals, along with operation of Palo Alto Food Closet. Healthcare services Awarded $135,374 (HSRAP) to Ravenswood Family Health Network for healthcare services for low income and unhoused Palo Altans and $10,000 (Emerging Needs grant) to update its Optometry care for higher quality of care to low- income and unhoused clients. Miscellaneous services for the unhoused Awarded $735 (mini grant) for various services for the unhoused including (car repair, storage fees, and dental etc.) Item 3 Item 3 Staff Report        Item 3: Staff Report Pg. 8  Packet Pg. 18 of 489  Safe Parking Program Funded $447,849 to expand safe parking operations at 2000 Geng Road, adding 10 oversized vehicle spaces After receiving comments and feedback from Council at the study session, the County will continue to gather feedback from the community, including at an April 30th event at Mitchell Park, before bringing the final Plan to the County Board of Supervisors in late summer/early fall. Following Board approval, staff will work with the County to bring the final plan back to Council for review and endorsement. For a more detailed timeline, please see Attachment C: Santa Clara County Community Plan timeline. FISCAL/RESOURCE IMPACT This report is informational and has no direct fiscal impact. However, the data informs future resource allocation, program planning, and service capacity needs. STAKEHOLDER ENGAGEMENT The City meets with the County monthly on topics relating to supportive housing, including the draft Plan. In addition to a variety of interviews, focus groups and steering committee meetings held since spring 2025 throughout Santa Clara County, there was also a north-county specific focus group held in Palo Alto focused on people with lived experience. As mentioned earlier in the report, there is an additional community engagement opportunity in Palo Alto on April 30, from 6-8 pm at Mitchell Park in the El Palo Alto room. ENVIRONMENTAL REVIEW This item is not a project as defined by the California Environmental Quality Act because is a study session with no action required by the Council. ATTACHMENTS Attachment A: Santa Clara County Draft Community Plan to End Homelessness Attachment B: Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto) Attachment C: Santa Clara County Community Plan Timeline APPROVED BY: Ed Shikada, City Manager Item 3 Item 3 Staff Report        Item 3: Staff Report Pg. 9  Packet Pg. 19 of 489  3.3.26 Draft 1 Santa Clara County: Community Plan to End Homelessness Focus Area 1 Prevent people from becoming homeless. Strategy A – Expand programs and investments to prevent people from becoming homeless. Sub-Strategies A1: Increase public and private funding for homelessness prevention programs. A2: Strengthen and sustain a high-impact homelessness prevention system. A3: Align policy and affordable housing investment to improve housing stability for households at-risk of homelessness. Strategy B – Ensure services are effective to prevent people from becoming homeless. Sub-Strategies B1. Prevent evictions through early identification, tenant protections, and system coordination. B2: Enforce fair housing protections and increase access to legal services to combat housing discrimination. B3: Leverage health care resources to prevent homelessness. Strategy C – Enhance coordination across systems to prevent people from becoming homeless. Sub-Strategies C1: Prevent homelessness at discharge or system exit through coordination with health care or behavioral health institutions, foster care, or criminal legal systems. Item 3 Attachment A - Santa Clara County Draft Community Plan to End Homelessness        Item 3: Staff Report Pg. 10  Packet Pg. 20 of 489  Draft 3.3.26 2 C2: Establish partnerships to increase income and employment for those at-risk of homelessness. C3: Strengthen partnerships with safety net services for a community-driven approach to preventing homelessness. Focus Area 2 Continue to house people and support them in retaining their housing. Strategy A – Increase and maintain a continuum of housing options that meets the need. Sub-Strategies A1: Increase public and private funding to build more permanent housing and implement system improvements. A2: Increase public and private funding to expand temporary housing capacity and implement system improvements. A3: Prioritize development of housing for extremely low-income individuals and families making 30% of Area Median Income or less and set joint targets. A4: Build up programs and services to reach geographically underserved areas of the county. A5 Strengthen and diversify permanent housing capacity and options to meet varied needs and acuity levels. A6: Strengthen and diversify temporary housing capacity and options, including Emergency Interim Housing (EIH), to meet varied needs and acuity levels. A7: Co-design innovative and inclusive housing and service models with people with lived experience that expand access to diverse, permanent housing solutions. Strategy B – Increase consistency, diversity, and quality of housing and services for people accessing the housing continuum. Sub-Strategies B1: Standardize high-quality service delivery and individualized care across the housing continuum. Item 3 Attachment A - Santa Clara County Draft Community Plan to End Homelessness        Item 3: Staff Report Pg. 11  Packet Pg. 21 of 489  Draft 3.3.26 3 B2: All housing continuum programs are safe, healthy, and accessible to everyone. B3: Improve tenancy support for participants in permanent housing programs. B4: Invest in equitable workforce development programs for people with lived experience within the homeless system. B5: Promote skill-building and career advancement opportunities for people with lived experience within the homeless system. B6: Support the development and implementation of programs led by people with lived experience that provide peer support, housing navigation, and mentorship. Strategy C – Improve system coordination throughout the housing continuum. Sub-Strategies C1: Reduce returns to homelessness and program exits. C2: Increase coordination between property management and service providers to ensure housing stability. C3: Reduce housing search time and expand landlord capacity for scattered site housing programs. Focus Area 3 Strengthen access to care and services for people experiencing unsheltered homelessness. Strategy A – Build capacity and expand access to trusted, culturally responsive, and coordinated services and resources throughout Santa Clara County. Sub-Strategies A1: Identify sustainable funding for increased access to care and services for people experiencing unsheltered homelessness. A2: Prioritize peer-led and community-driven outreach and communications models to effectively serve underserved regions and populations who are historically underserved or overrepresented in the homeless system. A3: Improve system-wide access to real-time, understandable, and comprehensive resource information and availability. Item 3 Attachment A - Santa Clara County Draft Community Plan to End Homelessness        Item 3: Staff Report Pg. 12  Packet Pg. 22 of 489  Draft 3.3.26 4 Strategy B – Increase consistency, variety, and quality of outreach, basic, and essential needs services. Sub-Strategies B1: Expand service delivery offerings for basic and essential needs and to support stability. B2: Ensure that service providers are equipped with the skills, capacity, and ability to effectively serve those in unsheltered situations. B3: Create a consistent, person-centered approach to address vehicular homelessness. B4: Connect impacted populations to culturally responsive services. Strategy C – Invest in approaches that improve outcomes and reduce harm for people living unsheltered and the community at-large. Sub-Strategies C1: Strengthen coordination between behavioral health, homeless service providers, and public safety partners to divert non-violent homeless-related calls away from law enforcement. C2: Expand re-entry and behavioral health services as alternatives to arrest or emergency room admission. C3: Decrease the number of people residing in encampments and reduce criminalization of homelessness for those who are unsheltered Focus Area 4 Center and invest in people with lived experience to lead and transform the homeless system. Strategy A – Expand the representation of people with lived experience in leadership roles and decision-making bodies. Sub-Strategies A1: Build capacity of local jurisdictions and organizations to increase lived experience in leadership roles and decision-making bodies A2: Create accessible and flexible leadership opportunities that consider varying interests, availability, and backgrounds Item 3 Attachment A - Santa Clara County Draft Community Plan to End Homelessness        Item 3: Staff Report Pg. 13  Packet Pg. 23 of 489  Draft 3.3.26 5 A3: Reduce structural barriers to participation. Strategy B – Build leadership capacity and advancement pathways for people with lived experience. Sub-Strategies B1: Provide opportunities such as mentorship and education for people with lived experience to establish pathways for leadership advancement. B2: Support transitions from advisory roles to formal decision making and leadership positions. B3: Advance equity in hiring, advancement, and retention of people with lived experience. Strategy C – Equip homeless system partners to effectively partner with people with lived experience. Sub-Strategies C1: Establish standards and best practices to support authentic lived experience engagement C2: Formalize processes to regularly evaluate the quality and depth of lived experience engagement and use findings to drive improvement. C3: Develop clear accountability measures to transparently demonstrate how lived experience input informs decisions and system change. Item 3 Attachment A - Santa Clara County Draft Community Plan to End Homelessness        Item 3: Staff Report Pg. 14  Packet Pg. 24 of 489  City of Palo Alto Report, CY2025 (January 1, 2025 to December 31, 2025) Office of Supportive Housing, Santa Clara County Santa Clara County Overview Homelessness in Santa Clara County and the City of Palo Alto  Measure of Homelessness Measures of Homelessness (and Housing Placements) Currently on the Community Housing Queue, as of January 30, 2026 Homeless in CY2025: Total VI‐SPDAT assessments completed in CY2025 The CY2025 Santa Clara County Supportive Housing System (Active program enrollments during CY2025) Households Project Type Enrolled Housed (if applicable) Enrolled Housed (if applicable)Enrolled Housed Permanent Supportive Housing (disability required)4,556        4,331                                219            214                                    4.8%4.9% Rapid Rehousing 1,679        1,276                                74              57                                      4.4%4.5% Emergency Housing Voucher Program 653            642                                    26              26                                      4.0%4.0% Emergency Shelter 5,102        NA 272            NA 5.3%NA Transitional Housing 529            NA 16              NA 3.0%NA Safe Parking 550            NA 72              NA 13.1%NA Street Outreach 5,194        NA 187            NA 3.6%NA Housing Problem Solving 4,530        NA 203            NA 4.5%NA Services Only (Includes UPLIFT)8,944        NA 563            NA 6.3%NA Homelessness Prevention 3,121        NA 29              NA 0.9%NA Emergency Shelter enrollments have increased as the capacity of shelter programs increased from 2,158 units in December 2024 to 2,968 units in December 2025. Santa Clara County 10,711 people were experiencing homelessness  in Santa Clara County (an increase of 8% from  9,903 in 2023) ∙         7,472 (70%) of them were unsheltered and  3,239 (30%) were sheltered Santa Clara County 5,311 households 8,614 households o   3,858 households requested housing  o   2,012 households were placed in permanent  City of Palo Alto 418 people were experiencing homelessness in  the City of Palo Alto  (an increase of 103% from  206 in 2023) ∙         399 (95%) of them were unsheltered City of Palo Alto Affiliated 187 households 297 households o   154 households requested housing assistance  Notes: Only Head of Household data are shown for these reports as planning for housing developments is done at the household level. Households may be enrolled in more than one program type within the reporting period. Homelessness Prevention city affiliation definition is based on the current zip code of the head of household at program enrollment. o   71 households were placed in permanent  As we are implementing effective solutions and slowing the growth of the crisis, Santa Clara County saw a 5% decrease in CY2025 in homeless inflow (people seeking homelessness assistance for  the first time) compared to CY2024 and a 19% decrease in homeless inflow since CY2019 (the baseline year for the Community Plan). We must summon the collective will and resources to not only  respond to the current crisis and scale our successful housing strategies, but also address and eliminate the root causes of homelessness in our community.  By pooling our resources and  coordinating our efforts, each city’s investment will be multiplied and will maximize our efforts to expand the supportive housing system and end homelessness in Santa Clara County. We hope this  bi‐annual report will support your City in meeting the need in your jurisdiction, as well as connect your strategies to county‐wide efforts.  •       27,037 people  (19,243 households) were served through temporary housing which consists of emergency shelter, transitional housing, and safe parking •       Supportive Housing (i.e., Permanent Supportive Housing and Rapid Rehousing) capacity increased by 29% with a total of 6,400 units/subsidies and 1,041 units in the pipeline •       Temporary housing (Emergency shelter, Transitional housing, and Safe Parking) capacity increased by 82% with a total of 3,420 units and over 280 shelter units in the pipeline Link to most recent progress report: 2020‐2025 Community Plan to End Homelessness Through a collective impact response implementing the 2020‐2025 Community Plan to End Homelessness, Santa Clara County housed over 3,300 people (about 2,012 households) in CY2025. This  continued progress speaks to the efforts of partners working collaboratively on shared goals. Since January 2020 (through December 2025): •       20,830 people were connected to permanent housing (12,362 households) •       Prevention programs reached 38,060 at‐risk people (20,341 households) Percent of Total SCCCity of Palo Alto Affiliated Point‐in‐Time Count, January 2025 System Inflow (First time VI‐SPDAT) & Outflow (Housing Placements), CY2025 Santa Clara County Summary Charts Page 1 of 2 Item 3 Attachment B - Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto)        Item 3: Staff Report Pg. 15  Packet Pg. 25 of 489  Summary Chart of City of Palo Alto Affiliated Program Enrollments Project Type Enrolled Homelessness Prevention 29               Services Only (Includes UPLIFT)563             Housing Problem Solving 203             Street Outreach 187             Safe Parking 72               Transitional Housing 16               Emergency Shelter 272             Emergency Housing Voucher Program 26               Rapid Rehousing 74               Permanent Supportive Housing (disability required)219             29  563  203  187  72  16  272  26  74  219  0 100 200 300 400 500 600 HOMELESSNESS PREVENTION SERVICES ONLY (INCLUDES UPLIFT) HOUSING PROBLEM SOLVING STREET OUTREACH SAFE PARKING TRANSITIONAL HOUSING EMERGENCY SHELTER EMERGENCY HOUSING VOUCHER PROGRAM RAPID REHOUSING PERMANENT SUPPORTIVE HOUSING (DISABILITY REQUIRED) City of Palo Alto: Household Program Enrollments during CY2025 Summary Charts Page 2 of 2 Item 3 Attachment B - Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto)        Item 3: Staff Report Pg. 16  Packet Pg. 26 of 489  Homeless Inflow ‐ First Time VI‐SPDAT (Households) Calendar Year Total Homeless Inflow  (Santa Clara County) City of Palo Alto  Affiliated Inflow Percent of  Total 2019 4,744 138 2.9% 2020 3,419 139 4.1% 2021 3,156 173 5.5% 2022 3,440 153 4.4% 2023 4,267 162 3.8% 2024 4,071 126 3.1% 2025 3,858 154 4.0% Households Placed in Permanent Housing Calendar Year Total Housed (Santa  Clara County) City of Palo Alto  Affiliated Housed Percent of  Total 2019 1,947 87 4.5% 2020 2,099 80 3.8% 2021 1,943 65 3.3% 2022 2,060 64 3.1% 2023 2,509 80 3.2% 2024 2,234 65 2.9% 2025 2,012 71 3.5% City of Palo Alto Affiliated Households Homeless Inflow Housed 2019 138 87 2020 147 80 2021 180 65 2022 165 64 2023 168 80 2024 127 65 2025 154 71 138 147 180 165 168 127 154 87 80 65 64 80 65 71 2019 2020 2021 2022 2023 2024 2025 City of Palo Alto: Homeless Inflow and Permanent Housing  Placements Homeless Inflow Housed Trends Page 1 of 1 Item 3 Attachment B - Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto)        Item 3: Staff Report Pg. 17  Packet Pg. 27 of 489  Demographics for 297 VI‐SPDAT Assessments Completed in CY25, City of Palo Alto: This represents an indicator of homelessness in CY25 for households affiliated with the City of Palo Alto Note: Data not shown for groups with fewer than 11 respondents Permanent  Supportive  Housing, 146,  49%Rapid Rehousing,  131, 44% Minimal Range,  20, 7% By Level of Need (Based on VI‐SPDAT Score) 4%, 11 4%, 11 4%, 12 8%, 25 22%, 64 27%, 79 32%, 95 0 20 40 60 80 100 Jail (Completed a JD‐VI‐ SPDAT) Other/ Data not collected Transitional Housing Couch Surfing Shelters/ Safe Haven/ Motel Outdoors Car/RV/Trailer/Van Where do you sleep most frequently? Demographics Page 1 of 7 Item 3 Attachment B - Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto)        Item 3: Staff Report Pg. 18  Packet Pg. 28 of 489  8%, 23 15%, 44 22%, 64 22%, 63 18%, 52 17%, 51 0 10 20 30 40 50 60 70 18 to 24 25 to 34 35 to 44 45 to 54 55 to 64 65 or Above By Age Tier 55%, 163 14%, 41 11%, 33 8%, 25 11%, 34 0 20 40 60 80 100 120 140 160 180 2 years or more 1 ‐ 2 years 6 months to 1 year 3 ‐ 6 months Less than 3 months How long has it been since you lived in permanent stable housing? Demographics Page 2 of 7 Item 3 Attachment B - Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto)        Item 3: Staff Report Pg. 19  Packet Pg. 29 of 489  Single Adults,  237, 80% Families with  Children, 44,  15% Single Youth and Young  Adults, 16, 5% By Household Type Man, 180, 61% Woman/  Additional  Gender  Identities, 117,  39% By Gender Demographics Page 3 of 7 Item 3 Attachment B - Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto)        Item 3: Staff Report Pg. 20  Packet Pg. 30 of 489  5%, 16 8%, 25 27%, 79 34%, 102 32%, 95 0 20 40 60 80 100 120 American Indian, Alaska Native, or Indigenous/ Other Asian or Asian American Black, African American, or African Hispanic/ Latina/e/o White (Non‐Hispanic/ Latina/e/o) By Race and Ethnicity (Multiple Responses Allowed) 15%, 44 29%, 86 30%, 88 62%, 185 0 50 100 150 200 Drinking or Drug Use Cause Lose Housing Mental Health or Brain Issues Affect Housing Physical Disability Limit Housing Options Homelessness caused by abuse or trauma By Self‐Reported Disability/Vulnerability (VI‐SPDAT) Demographics Page 4 of 7 Item 3 Attachment B - Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto)        Item 3: Staff Report Pg. 21  Packet Pg. 31 of 489  Demographics for 8,614 Total VI‐SPDAT Assessments Completed in CY25 in Santa Clara County These charts provide information if you would like to compare individual city results with results for the entire county. Note: Data not shown for groups with fewer than 11 respondents Permanent  Supportive  Housing, 5,273 ,  61% Rapid  Rehousing,  2,810 , 33% Minimal Range,  531 , 6% SCC: By Level of Need (Based on VI‐SPDAT Score) 3%, 263  4%, 337  6%, 492  8%, 656  19%, 1,600  22%, 1,887  39%, 3,379   ‐  500  1,000  1,500  2,000  2,500  3,000  3,500  4,000 Other/ No Response Transitional Housing Jail Couch Surfing Shelters/ Safe Haven/ Hotel/ Motel/ Treatment Facility Car/RV/Trailer/Van Outdoors SCC: Where do you sleep most frequently? Demographics Page 5 of 7 Item 3 Attachment B - Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto)        Item 3: Staff Report Pg. 22  Packet Pg. 32 of 489  1%, 61  62%, 5,357  13%, 1,101  8%, 657  6%, 549  9%, 737  2%, 152   ‐  1,000  2,000  3,000  4,000  5,000  6,000 Data not collected 2 years or more 1 ‐ 2 years 6 months to 1 year 3 ‐ 6 months 1 week ‐ 3 months Less than a week SCC: How long has it been since you lived in permanent stable housing?  9%, 812  19%, 1,664  25%, 2,183  20%, 1,728  17%, 1,471  9%, 745   ‐  500  1,000  1,500  2,000  2,500 18 to 24 25 to 34 35 to 44 45 to 54 55 to 64 65 or Above By Age Tier Single Adults,  6,790 , 79% Families with  Children, 1,287  , 15% Single Youth  and Young  Adults, 537 ,  6% SCC: By Household Type (Based on VI‐SPDAT Type) Demographics Page 6 of 7 Item 3 Attachment B - Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto)        Item 3: Staff Report Pg. 23  Packet Pg. 33 of 489  Man, 5,237 ,  61% Woman, 3,263  , 38% Additional  Gender  Identities, 114  , 1% SCC: By Gender 7%, 608 7%, 569  15%, 1,301  53%, 4,527  1%, 47 2%, 180  24%, 2,107   ‐  500  1,000  1,500  2,000  2,500  3,000  3,500  4,000  4,500  5,000 American Indian, Alaska Native, or Indigenous Asian or Asian American Black, African American, or African Hispanic/ Latina/e/o Middle Eastern or North African Native Hawaiian or Pacific Islander White (Non‐ Hispanic/ Latina/e/o) SCC: By Race and Ethnicity (Multiple Responses Allowed) 27%, 2,356  29%, 2,525  35%, 3,009  67%, 5,757   ‐  1,000  2,000  3,000  4,000  5,000  6,000  7,000 Drinking or Drug Use Cause Lose Housing Physical Disability Limit Housing Options Mental Health or Brain Issues Affect Housing Homelessness caused by abuse or trauma SCC: By Self‐Reported Disability/Vulnerability (VI‐SPDAT) Demographics Page 7 of 7 Item 3 Attachment B - Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto)        Item 3: Staff Report Pg. 24  Packet Pg. 34 of 489  Notes and Definitions •      Enrollment and assessment data is from HMIS (Homeless Management Information System) •      Inflow:  First time a person/household completes a VI‐SPDAT assessment (Note that only the head of  household of a household with children is instructed to take the Family VI‐SPDAT assessment) •      Outflow: Households placed in permanent housing (a move‐in date in a housing program or an exit to a  permanent housing destination from a non‐housing program). Total (Santa Clara County) numbers include HUD‐ VASH housing (PSH) placements but city‐level data does not include most HUD‐VASH clients (since city affiliation  Notes about City Affiliation: •       City affiliation is based on client self‐reported data from 4 city affiliation questions (provided during an  assessment) and one program enrollment field: o   In which city do you spend most of your time? o   Which city did you live in prior to becoming homeless? o   If you are employed, in which city is your work place? o   If you (or your children) go to school, in which city is your school? o   Zip Code of last permanent address (Program Enrollment) •     Zip Codes used in the analysis for the City of Palo Alto: 94301, 94302, 94303, 94304, 94306, 94309 •       City affiliation for homeless inflow and Community Housing Queue data is based on VI‐SPDAT questions only. •       City affiliation for housing placements is based on the most recent VI‐SPDAT assessment and program  enrollment (zip code of last permanent address). •       City affiliation for most program enrollments is based on the most recent of any assessments that have a city  affiliation questions (VI‐SPDAT, Community Hotline/Triage, Housing Problem Solving, Homelessness Prevention)  and program enrollment (zip code of last permanent address). •       City affiliation for Housing Problem Solving is based on the Housing Problem Solving Assessment 4 city  •       City affiliation for Homelessness Prevention is based on Zip code of current address at program enrollment. •       Street Outreach enrollments do not include Safe Parking enrollments as they are reported separately. •     Housing Problem Solving services include financial assistance, mediation, and attempts by case managers in  person or by phone. •       Homelessness Prevention includes only HPS‐DH and HPS‐OSH (EAN) programs. Note about Race and Ethnicity With the new 2024 HMIS data standards, Race and Ethnicity is now one question (previously it was 2 questions)  and Hispanic/Latina/e/o was added to the list of Race and Ethnicity options as well as Middle Eastern/North  African. Clients may choose more than one race and ethnicity option. We show the responses for each race and  consequently; the numbers do not add up to 100%. Notes Page 1 of 1 Item 3 Attachment B - Santa Clara County Office of Supportive Housing Calendar Year 2025 Report (Palo Alto)        Item 3: Staff Report Pg. 25  Packet Pg. 35 of 489  1 2025-2030 COMMUNITY PLAN TIMELINE Spring 2025 – Summer/Fall 2026 Onboarding of Steering Committee Qualitative & Quantitative Analysis Spring 2025 Qualitative Data Collection Steering Committee drafts Sub- Strategies & Tasks Engagement with Cities Summer 2025 Continued engagement with Cities Convene lived experience work group Fall 2025 Engagement with Cities on Draft Plan Steering Committee finalizes Draft Plan Winter 2025–2026 Community Input on Draft Plan Begin Drafting Sub-Regional Plans Finalize Plan based on Community Input Spring 2026 CoC Board adopts Plan Endorsement from Jurisdictions Year 1 Implementation Begins Summer - Fall 2026 Item 3 Attachment C - Santa Clara County Community Plan Timeline        Item 3: Staff Report Pg. 26  Packet Pg. 36 of 489  2 NEXT STEPS June – Dec. 2026 Mar. – May 2026 Mar. – May 2026 Community Input Review of full draft plan Coordinate feedback from City leaders, lived experience & constituents Finalize Plan & Develop Sub- Regional City Plans Finalize plan based on Community Input Develop action steps and metrics based on regional needs Ensure alignment with existing City Plans & Strategies Plan Adoption and Endorsement by County and Cities CoC Board Adoption (June) Execute process to obtain BOS and City Council endorsement Plan for implementation Item 3 Attachment C - Santa Clara County Community Plan Timeline        Item 3: Staff Report Pg. 27  Packet Pg. 37 of 489  CITY COUNCIL Staff Report From: City Manager Report Type: STUDY SESSION Lead Department: Planning and Development Services Meeting Date: April 20, 2026 Report #: 2603-6074 TITLE 910 Webster Street [26PLN-00026]. Request for Council Prescreening to Rezone the Subject Property from RM-20 to Planned Community/Planned Home Zoning and to Allow Construction of 70 Residential Units in a Seven-Story Structure. CEQA Status: Not a Project. RECOMMENDATION Staff recommends that Council conduct a prescreening and provide informal comments regarding the applicant’s request to rezone 910 Webster Street from Low Density Multiple- Family Residence District (RM-20) to Planned Community/Planned Home Zoning (PHZ). Comments provided during the prescreening process are not binding on the City nor the applicant. EXECUTIVE SUMMARY This prescreening is a request by the applicant to rezone the subject property, which is currently zoned Low Density Multiple-Family Residence District (RM-20) to Planned Home Zoning (PHZ). 1 The project includes deconstruction of an existing 24-unit apartment complex and redevelopment of the 1.15 acre site with 70 residential condominium or apartment units, 20% of which would be provided at below market rate. In accordance with Palo Alto Municipal Code (PAMC) Section 18.79.030(A), a prescreening review is required for legislative changes, including rezoning, prior to submittal of a formal application. Prescreenings are intended to solicit early feedback on proposed projects and, like all study sessions, cannot result in any formal action. Since this proposal may return to the City Council as a formal application, Councilmembers should refrain from forming firm opinions supporting or opposing the project. 1 Referred to in this report as "Planned Home Zoning" to emphasize the focus on housing as the benefit to the community. PAMC Section 18.38, which outlines the requirement and process for Planned Community (PC) Zoning, remains the underlying code supporting application of this policy. Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 1  Packet Pg. 38 of 489  Following this prescreening, the applicant may choose to file a formal application to amend the zoning for the site. Planned Community Rezoning applications require an initial review by the Planning and Transportation Commission (PTC) followed by a formal recommendation from the Architectural Review Board, a formal recommendation from the PTC, and Council’s final decision as set forth in PAMC Chapter 18.38. BACKGROUND ANALYSIS Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 2  Packet Pg. 39 of 489  summarizes staff’s preliminary review of the proposal and highlights key policy considerations associated with the applicant’s request. A 2.69:1 FAR where a maximum of 0.5 FAR is allowed for multi-family residential use; 48% lot coverage where a maximum of 35% is allowed (an additional 5% is allowed for covered patios and overhangs); 81 feet and six inches tall where a maximum of 35 feet in height is allowed (This does not include the height of the cupola, which extends to 92 feet and nine inches); An interior side yard and rear yard daylight plane with a 10-foot initial height and 65- degree angle where a 10-foot initial height and 50-degree angle is required; and 130 vehicle parking spaces where 140 parking spaces are required (~7% reduction). PC Special Requirements Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 3  Packet Pg. 40 of 489  The project would be subject to special standards for PC districts under PAMC Section 18.38.150(c), (d), and (e). Based on the information provided, the project is not consistent with (e), and consistency with (d) cannot be determined. Staff requests that Council provide feedback on each of these areas. Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 4  Packet Pg. 41 of 489  requirements. The RM-20 zone has a maximum density of 20 units per acre. The highest density achievable under State Density Bonus Law would be 40 units per acre (with a 100% bonus). This is well below the 61 du/ac proposed; additionally, the applicant would be required to provide a significantly higher percentage of the units at BMR in order to achieve this density increase in addition to providing those units to lower income levels. Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 5  Packet Pg. 42 of 489  The proposal would require the demolition of 24 existing apartment units to be replaced by a potential mix of 70 condominium and apartment units. When existing residential rental units are being demolished, the landlord must comply with the City’s Rental Protection Requirements under PAMC Chapter 9.68 including proper noticing and relocation assistance. In particular, for a just-cause no-fault eviction, the landlord must offer the existing tenants relocation assistance in one of two ways: 3 provides greater weight and flexibility towards providing very-low income units. At this time, the applicant is proposing the equivalent of 20.1% BMR units (12 units) distributed throughout the project, but noted to staff that they may utilize a different option if/when they submit a formal application. The plans don’t identify specific locations for the BMR units, but a breakdown of how many units are proposed at the various income levels has been provided in the table below. Per the Affordable Housing Plan Specifications Form (Item 3), the applicant shall provide a detailed description and chart of each BMR unit's: size, and type relative to the total number of units to verify the project meets the 20% threshold. 3 June 23, 2020 Council staff report. https://www.paloalto.gov/files/assets/public/v/1/agendas-minutes- reports/reports/city-manager-reports-cmrs/year-archive/2020/id-10715.pdf Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 6  Packet Pg. 43 of 489  Source: Attachment C FISCAL/RESOURCE IMPACT There is no fiscal or resource impact associated with the recommendation in this report. A future project, if filed, approved and constructed, would generate higher property tax revenue and add residents that would like support in some measure the local economy. A future project would also be subject to development impact fees to address its effects on public services and infrastructure. The precise magnitude of these impact fees will be refined as the application and proposed project advances. STAKEHOLDER ENGAGEMENT The Palo Alto Municipal Code requires notice of this public meeting 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 and postcard mailing for this project was published in the Daily Post on April 10, 2026, which is 10 days in advance of the meeting. As of the writing of this report, staff received 11 written comments in Attachment D. The comments received by staff generally resolve around the following concerns: 1. Concerns with the height and scale of the proposed building in the context of the surrounding area and impacts on adjacent shorter structures. 2. Concerns on impacts to the quality of life, sunlight, and privacy impacts for existing residents and tenants of the surrounding properties. 3. Concerns around increases to traffic and congestion by increasing the density to the property; especially as it relates to senior citizens and children from nearby schools 4. Concerns around the availability of parking stalls for the site for future tenants 5. The first noted impacts on themselves and their tenants during and after construction while the second noted concerns around growing congestion and potential safety impacts that can create for seniors living at Channing House (850 Webster Street) which is across the street from this project. 6. Concerns surrounding daily operational impacts (noise, odor, etc.) from dining hall on adjacent uses. Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 7  Packet Pg. 44 of 489  Another member of the public called staff and expressed concerns about scale and transition to low density residential uses next to the site as well as availability of daylight. ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 8  Packet Pg. 45 of 489  24 Channing House Webster Oaks Apts. 50.0' 200.0' 50.0' 150.0' 50.0' 150.0' 50.0' 50.0' 112.5' 50.0' 112.5' 50.0' 112.5' 25.0' 12.5' 100.0' 50.0' 125.0'125.0' 50.0' 100.0' 50.0' 100.0' 50.0' 60.0' 150.0' 60.0' 150.0' 90.0' 150.0' .0' 50.0' 200.0' 75.50.0' 75.0'200.0 50.0' 62.5' 50.0' 0.0'150.0'74.7' 0' 200.0' 50.0' 62.5' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 150.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 200.0' 100.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 100.0' 90.0'100.0' 90.0' 200.0' 250.0' 200.0' 250.0' 100.0' 50.0' 100.0' 50.0' 50.0' 150.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 100.0' 75.0'100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 150.0' 150.0' 150.0' 150.0' 200.0' 100.0' 200.0' 100.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 200.0' 250.0' 100.0' 175.0' 100.0' 75.0' 85.0' 200.0' 67.0' 50.0' 133.0' 70.0'90.0' 40.0' 25.0' 40.0' 100.0' 60.0' 100.0' 60.0' 200.0' 50.0' 200.0' 50.0' 200.0' 50.0' 200.0' 50.0'200.0' 62.5' 200.0' 62.5' 200.0' 50.0' 200.0' 50.0' 100.0' 37.5' 100.0' 37.5' 200.0' 62.5' 200.0' 62.5' 112.5' 50.0' 125.0' 50.0' 125.0' 50.0' 133.0' 50.0' 133.0' 50.0' 90.0' 40.0' 90.0' 40.0' 115.0' 40.0' 115.0' 40.0' 115.0' 50.0' 115.0' 50.0' 115.0' 50.0' 115.0' 50.0' 200.0' 62.5' 200.0' 62.5' 200.0' 62.5' 200.0' 62.5' 200.0' 62.5' 200.0' 62.5' 200.0' 62.5' 200.0' 62.5' 140.0' 50.0' 140.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 100.0' 37.5' 100.0' 37.5' 100.0' 37.5' 100.0' 37.5' 100.0' 75.0'100.0' 75.0' 200.0' 200.0' 90.0' 50.0' 75.0' 50.0' 75.0' 50.0' 75.0' 50.0' 75.0' 100.0' 37.5' 100.0' 37.5' 100.0' 175.0' 100.0' 175.0' 400.0' 250.0' 400.0' 126.0' 38.0' 126.0' 100.0' 45.0' 100.0' 45.0' 100.0' 40. 100.0' 40.0' 100.0' 50.0' 100.0' 20 50.0' 50.0' 100.0' 50.0' 10 100.0' 150.0' 200.0' 50.0' 200.0' 12.0' 126.0' 50.0'200.0' 50.0' 200.0' 200.0' 50.0' 200.0' 200.0' 50.0' 200.0' 200.0' 50.0' 200.0' 200.0' 50.0' 200.0' 200.0' 50.0' 200.0' 200.0' 210.0' 400.0' 500.0' 623-635 609-621 601-605 600-604 664 608-620 624-638 -680 660-666 640-656 940 924-936 908-920 905 925-937 961-973 993-997 975-989 945-957 909-921 825 837 569 451 460 532 -563 809- 823 936-940 933-935 556- 596 904- 926 538 527-533 530 835 899 940 901 941 539 541 543545 547 529 501 503 505 507 509 521 523 525 527 519 521 537 551 575 510 520 526 536 558 560 566 574 580561 827 829 845 847 619 615 637 645 934 581 850 567 569 838 846 513511 917 915 913 907 520 518 911909 905 903 923 925 939 945 505 965 971 468 926 918 912 904 483 515 517 519 531 533 535 537 459 471 633 1022 1026 627 629 938 595 76 855 940A 540 542 544 546 548 552 931 507 HOMER AVENUE COWPER STREET CHANNING AVENUE ADDISON AVENUE WEBSTER STREET WEBSTER STREET CHANNING AVENUE CHANNING AVENUE COWPER STREET LANE 56 RM-20 PC-2836PC-8659 PC- Channing House This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend Special Setback Frontages Park School abc Building Roof Outline Underlying Lot Line abc Easement abc Lot Dimensions Zone Districts abc Zone District Labels City Jurisdictional Limits: Palo Alto City Boundary Tree Current Features 0' 127' CITY OF PALO ALTO I NC O R P O R A TE D CALI FORNIA P a l o A l t o T h e C i t y o f APRI L 1 6 189 4 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Alto smckay, 2026-03-12 11:49:27 Location Map (Basic) (\\cc-maps\Encompass\Admin\Personal\Planning.mdb) Item 4Attachment A - LocationMap       Item 4: Staff Report Pg. 9  Packet Pg. 46 of 489  ATTACHMENT B 910 Webster Street, 26PLN-00026 Table 1: COMPARISON WITH CHAPTER 18.13 (RM-20 DISTRICT), 18.14 (HOUSING INCENTIVE PROGRAM (HIP) and 18.38.150 (PC SPECIAL REQUIREMENTS) Development Standards Regulation Required Proposed Residential Project Minimum Site Area, width and depth 8,500 sf, 70 feet, 100 feet None for HIP 50,000 sf (1.15 acres) Minimum Front Yard 20 feet 10 feet for HIP 22 feet Rear Yard 10 feet 10 feet for HIP 22 feet Interior Side Yard 10 feet 10 feet for HIP 15 feet Street Side Yard 16 feet 8 feet for HIP 22 feet Max. Site Coverage 35% (17,500 sf) 70% for HIP 48% (24,018 sf) RM-20 Max. Building Height 30 feet 40 feet for HIP 81 feet 6 inches 92 feet 9 inches (to top of cupola) PC Special Requirements for Setbacks 10 feet for interior side and rear 15 feet (side); 22 feet (rear) PC Special Requirements for height 35 ft when within 150 feet of R-1, no restriction otherwise. 81 feet 6 inches 92 feet 9 inches (to top of cupola) Daylight Plane for side and rear lot lines for sites abutting any R-1, R- 2, or RM-20 district. 10-foot initial height and 45- degree angle 16-foot & 45-degree angle HIP 10-foot initial height and 65- degree angle PC Special Requirements for Daylight Plane 10-foot initial height and 50- degree angle 10-foot initial height and 65- degree angle Max. Floor Area Ratio (FAR)0.5:1 (25,000 sf) 2.0:1 for HIP (100,000 sf) 2.69:1 (135,073) Residential Density 20 du/ac per RM-20 Zone 40 du/ac for HIP 61 DU/AC (70 units proposed) Minimum Useable Open Space 150 sf per unit Open Space Provided: 13,606 sf + or 194 sf per unit Item 4 Attachment B - Zoning Comparison Table        Item 4: Staff Report Pg. 10  Packet Pg. 47 of 489  Table 2: CONFORMANCE WITH CHAPTER 18.52 (Off-Street Parking and Loading) Type Required Proposed Vehicle Parking 1 per unit 1 bedroom or Studio 2 per unit 2+ bedroom 128 spaces total 130 spaces proposed Bicycle Parking 1 LT space per unit (70) 1 ST space per 10 units (7) 119 spaces Loading Space 1 car loading space for a building with 50+ units None Item 4 Attachment B - Zoning Comparison Table        Item 4: Staff Report Pg. 11  Packet Pg. 48 of 489  1885 El Camino Real, Palo Alto, CA 94306 • 650 322 2288 • FAX: 650 322 2316 • architects@carrasco.com A Professional Corporation CARRASCO & ASSOCIATES A R C H I T E C T S PROJECT DESCRIPTION “910 WEBSTER STREET” HIGH DENSITY RESIDENTIAL CONDOMINUM UNITS Project Overview The proposed development “910 Webster Street” is a high-density residential community designed to integrate seamlessly into the Downtown Palo Alto context. The project balances the objective of maximizing housing density with a sensitive architectural approach that prioritizes neighborhood compatibility, environmental sustainability, resident well-being and sense of community. Project will include 20% affordable housing units distributed throughout the project. Massing, Solar Access, and Daylight Plane The building’s envelope is the result of rigorous solar geometry analysis (refer to Sheets T.1.03 and T.1.04). To protect the solar impacts to adjacent properties, the design implements a 65-degree Daylight Plane on the South and West elevations. · Shadow Study: Our study confirms that this massing eliminates shading on building structures to the south and west after 10:00 AM during the Winter Solstice. · Contextual Sensitivity: Shading impacts on the Channing House are minimized by directing shadows toward unfenestrated walls, while winter evening shadows are largely intercepted by the existing mature canopy of along the sidewalk of Webster Woods Apartment complex on Webster Street. Community and Pedestrian Orientation “910 Webster” project is centered around a lushly landscaped central courtyard, anchored by four shade trees and a 12-foot-wide circulation veranda. · Active Ground Floor: Indoor common areas, including the dining hall and fitness center, are oriented toward the courtyard to foster social interaction. · Urban Interface: Ground-floor units feature private front yards and individual street- front entries, reinforcing a "row-house" pedestrian scale and activating the Webster Street sidewalk. · Rooftop Amenities: A community library and terrace lounge provide diverse gathering spaces for residents. Item 4 Attachment C - Applicant’s Project Description Letter        Item 4: Staff Report Pg. 12  Packet Pg. 49 of 489  1885 El Camino Real, Palo Alto, CA 94306 • 650 322 2288 • FAX: 650 322 2316 • architects@carrasco.com A Professional Corporation Sustainability and Energy Performance The project aims for high energy autonomy, particularly regarding common area climate control. · Integrated PV System: Photovoltaic panels are utilized as a functional architectural cornice, providing both renewable energy production and passive solar shading for the upper floors. · Passive Climate Control: All balconies are equipped with operable Plantation Shutters, allowing residents to manually modulate natural ventilation, solar gain, and thermal comfort. Privacy and Residential Interface The floor plan is strategically programmed to respect the privacy of the adjacent low- density residential zone. · Acoustic and Visual Buffers: Bedrooms are primarily located on the south elevation. · Movable Screening: The floor-to-ceiling plantation shutters on all balconies provide a customizable visual buffer, protecting the privacy of both building residents and neighbors. Landscape and Tree Protection Recognizing Palo Alto’s commitment to its urban forest, the project is designed around the preservation of existing tree health. · Subterranean Setbacks: The underground garage is significantly set back (22’ on North, East, and West; 10’ on South) to ensure the root zones of neighboring trees remain undisturbed. · Permeability: The design maximizes permeable surface area through the central courtyard and perimeter setbacks to manage stormwater runoff effectively. Requested Concessions/Waivers/Incentives for Affordable Housing: FAR: 2.69 proposed Coverage: 50% proposed Stories: Six-story proposed Parking: 8% less vehicle parking Daylight Plane: 65° proposed angle Item 4 Attachment C - Applicant’s Project Description Letter        Item 4: Staff Report Pg. 13  Packet Pg. 50 of 489  From:Lauma Zunte To:Sauls, Garrett Cc:Aivars; Eriks Rungis; Indra Rungis; David Goldberg Subject:Proposed Residencial Highrise Date:Sunday, March 22, 2026 1:20:02 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Mr. Sauls, My name is Lauma Zunte and I own a small four unit apartment on 569 Addison Avenue in Palo Alto. Mr. David Goldburg reached out to me recently informing me of a proposed six story apartment complex going up just beyond my backyard fence. A massive structure as proposed will have a huge impact on my apartment complex. First on my mind is the idea of having such a large structure right next to my small two story building. Next is the impact on my residents when they go to the pool area that is right next to the common fence.The idea of six stories of prying eyes looking down on the pool area isn't too appealing. Additionally how it will impact the sun in the backyard is also a concern, A large project like this will involve untold months of demolition, clearing and then rebuilding. The noise and pollution alone will create a situation where many of my residents may choose to vacate their units. That will leave me in a financial crisis. These are a few of my immediate concerns that I hope will be considered if this project moves forward. Respectfully, Lauma Zunte This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report Powered by Mimecast Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 14  Packet Pg. 51 of 489  From:Steve Ludvik To:Sauls, Garrett Subject:Development on corner of Webster and Channing Ave Date:Wednesday, April 1, 2026 1:37:38 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Garrett, This letter is regarding the proposed 70 unit condominium development at the corner of Webster and Channing Ave. The development is poorly conceived and the council should reject the proposal. Channing Ave has become a heavily used thoroughfare between Alma and 101. Adding congestion from more street parked cars, maintenance services and delivery services (such as DoorDash) traffic will create safety hazards. The crossing at Webster/Channing has already experienced safety events. Safety: The proposed development is across the street from Channing House which supports seniors who often walk in the neighborhood. Adding unnecessary risks to their safety is a potential major liability for the city. I trust you are aware of the many lawsuits filed against the city, the outcome of which can far exceed any tax revenue or other perceived benefits to the city and its residents. Please consider these factors in your approval process. I hope that the City makes the correct decision and does not approve the development. Thank you for your support in this matter Sincerely, Steve Ludvik 541 Channing Ave Palo Alto CA 94301 This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 15  Packet Pg. 52 of 489  April 6, 2026 Garrett Sauls Project Planner City of Palo Alto garrett.sauls@paloalto.gov Subject: Concerns regarding the proposed 6-story development at 910 Webster St, Palo Alto, CA Dear Mr. Sauls: I am writing to you as an owner and resident at 532 Channing Ave, Unit 301, Palo Alto regarding a proposal that has been submitted to the city to develop a 6-story condominium building at 910 Webster St, Palo Alto. My unit sits next to the proposed condominium building. As a direct neighbor, I have significant concerns about the scale of this project. Our building stands at 3 stories, and the current building at 910 Webster is 1-2 stories. A 6-story structure would tower over our existing building, leading to several immediate impacts (note: although positioned as a 6-story building, there is a 7th floor that includes a community library): ● Loss of Natural Light: Many of our units rely on skylights and natural sun exposure that will be permanently blocked by a building of this height. ● Privacy: The significant height disparity would overlook our private living spaces and common areas. ● Neighborhood Character: A building of this density is a massive departure from the current 2 and 3-story profile of our immediate block. I am not opposed to new neighbors or a thoughtful development, but I believe this proposal is out of scale for this specific location. We are interested in advocating for a more balanced design—ideally limited to 3 stories —that respects the sunlight and privacy of the existing residents. Thank you for considering my concerns. I can be reached at for any questions: eric.c.yuen@gmail.com Mobile: 650-421-3202 Yours sincerely, Eric Yuen Owner and HOA Treasurer 532 Channing Ave, Unit 301, Palo Alto, CA 94301 Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 16  Packet Pg. 53 of 489  Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 17  Packet Pg. 54 of 489  From:Deborah Dooley To:Sauls, Garrett Subject:910 Webster Project Date:Saturday, April 4, 2026 10:44:52 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. I am writing this letter in response to the proposed project at 910 Webster St. The proposal suggests nearly tripling, 24 to 70 residents, the tenant population, and reducing the driveways from three to one. This one driveway in the center of a primary school corridor is unsafe and hazardous. This is going to maximize traffic problems, which already exist during school commuter hours. The 900 block of Webster is a high-density and high-traffic area, both for cars and pedestrians. This block is next to Addison Elementary School and one of the primary entrances to the school campus. The street, the parking, and the pedestrian traffic is extremely high during school commuter hours. At this time, there are currently parking problems, and the street that the proposal suggests one driveway for both entrances and exits will make this unsafe for the student population. Parking in this area is currently a problem due to over 100 Channing House employees parking on the streets, the Webster Wood, a high-density housing unit, tenant and guest parking on the streets, and Addison School parking on this block. As a private homeowner, there is often no parking available. This additional car parking will make parking a nightmare. Due to the single driveway, which will slow exiting, some tenants will use street parking, and guests will also park on the street. I have attached photos of street parking to show the current parking status. One driveway will slow garage parking traffic. This will result in more tenants parking on the street to avoid this. I have attached photos showing the dense parking currently in this block This proposal is showing minimal concern for the people who currently live in this neighborhood. The increase in traffic congestion, parking scarcity, noise pollution, environmental pollution, and the loss of natural sunlight to the neighborhood and its residents is at a high cost to current residents. I live next door, 934 Webster. This proposed single driveway will be 15 feet from my bedroom windows. 140 tenants using this single driveway will create noise and environmental pollution in my home. What is my recourse? There are enough congestion problems on this block without making what is already bad even worse. I encourage you to take a survey of school commute times to understand what a hazardous environment this proposal creates. There is a significant loss of sunlight to all surrounding residents. There is a significant loss of privacy to all surrounding residents. There is a significant increase in environmental pollution for all existing residents. This is a block that transitions from 2 and 3-story buildings to single-level homes. Adding a six-story home is not appropriate for this site. The streets cannot accommodate this. A building with this many tenants needs to be on a street with four lanes of traffic, not in a high- impact, congested area. Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 18  Packet Pg. 55 of 489  I have attached 3 parking pictures. These pictures are NOT during school commuting times. Deborah Dooley 934 Webster Street Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 19  Packet Pg. 56 of 489  From:David Goldberg To:Sauls, Garrett Subject:910 Webster Date:Friday, April 3, 2026 4:08:48 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Garrett Sauls, This letter is regarding the proposed 70 unit condominium development at the corner of Webster and Channing Ave, which would replace the Webster Oaks Apartments. The site is a good location for more housing, because it can support an increase in density and at the same time be respectful of the lower density neighbors. But the proposed design doesn't take advantage of that opportunity: it does increase the density but it towers above the neighboring homes, casting a large shadow. I urge that in return for rezoning the property, the council require the developer to be more sensitive to us lower density neighbors. Let me focus on the impacts on my own home, a condo bordering the west side of the proposed development, which has half the height and 1/3 the density. On the plus side, the proposal has 1.86 parking spots/unit, which is more than the existing apartment complex. And although parts of the proposed building are only 10 ft from our joint property line, the primary exterior wall is 22' away. Also, the architect has updated the plan to add more trees to visually screen our properties from one another. This is all good. But there is virtually no step down toward our homes on the west side. We will be facing an almost straight 6-story vertical wall. As a consequence, in the summer, the morning sun won't shine on our building until after 10:30 am. The illustration titled "Height Transition" on page 4 of their plans gives a visualization of how much the new condo would tower over our condo. None of this necessary, because there are designs for this site that would support a significantly increased density without having this negative impact on neighbors. The residents of this neighborhood purchased their homes in the belief that although we have one very tall building (Channing House), the rest would be a mixed-use neighborhood with buildings topping out at three stories. The proposed 6-story project strikes me as more of an initial bargaining offer than a serious proposal that would balance the amount of extra density against harmful impact to the rest of the neighborhood. In summary, please consider tying any rezoning with a requirement that the project be more suitable for this transitional location, by either lowering the height or having more step down. David Goldberg This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 20  Packet Pg. 57 of 489  532 Channing Ave #201 Palo Alto, CA Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 21  Packet Pg. 58 of 489  From:Catherine Cohen To:Sauls, Garrett Subject:Opposition to Rezoning Proposal – 910 Webster Street (Channing & Webster) Date:Friday, April 3, 2026 4:44:24 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Members of the Palo Alto City Council, I am writing to share my concerns regarding the proposed redevelopment of the Webster Oaks apartment building located at 910 Webster Street, at the corner of Channing Avenue and Webster Street. I live at 503 Channing Avenue, at the corner of Cowper and Channing, just one block from the proposed site. Given my proximity, I experience firsthand the current traffic, parking, and safety conditions in this area. The current proposal would replace an existing two-story, 24-unit apartment complex with a six-story, 70-unit condominium development, requiring rezoning of the site. While I support the need for additional housing in Palo Alto, I strongly oppose the rezoning of this site as currently proposed. This project, in its current form, raises significant concerns related to neighborhood compatibility, safety, and infrastructure impacts. Scale and Neighborhood Compatibility A six-story building is not consistent with the surrounding one / two story homes, with only a few 3 story apartment complexes. A six-story complex will fundamentally alter the character of this neighborhood. While Channing House is a 12-story structure nearby, it has been part of the community since the 1960s, and much of the surrounding neighborhood developed around it. It also functions more as a business/institutional use, bringing with it significant impacts, including more activity, delivery trucks, service vehicles, and emergency response vehicles blocking lanes. Residents in this area are already dealing with the impacts of that scale and use. For those living closest to Channing House, noise and activity, particularly near the loading and service areas are disruptive, with deliveries sometimes occurring as early as 3:00 AM. Introducing an additional high-density, multi-story development would further intensify these impacts and significantly change the dynamics of what is currently a residential neighborhood. This proposal risks creating a precedent for additional large-scale buildings without appropriate transition in height or density. A six-story structure would be out of character and This message needs your attention This is a personal email address. Mark Safe Report Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 22  Packet Pg. 59 of 489  disproportionately impactful in this setting. Traffic, Safety, and Congestion This area is already heavily impacted by traffic and presents real safety concerns, conditions that would be materially worsened by a development of this scale. Channing Avenue is a key thoroughfare to 101, with an elementary school just one block away. Children frequently walk and bike through this area. Vehicles traveling from Waverly toward Middlefield often exceed the 25-mph speed limit, making the Channing/Webster intersection particularly dangerous. Channing House delivery / service trucks and emergency vehicles frequently block one lane of this one-way street, causing ongoing traffic and safety issues. Residents of Channing House regularly walk in the neighborhood, further increasing the need for safe and predictable traffic conditions. Adding a development of this scale will significantly increase traffic in the area, and those impacts will not be limited to Webster Street, they will spill over onto Channing and further worsen an already constrained and impacted situation. The proposed development would significantly increase the number of residents and vehicles while consolidating access into a single driveway, which is likely to create additional congestion and bottlenecks at an already impacted intersection. Parking and Delivery Impacts Street parking in this area is already limited due to Channing House staff and visitors, school- related activity, and existing neighborhood demand. Currently, delivery and rideshare vehicles can pull into the existing property. With a larger, denser development and fewer access points, these vehicles will likely double park on surrounding streets, increasing congestion and creating additional safety risks. Commercial Use and Loading Dock Concerns I strongly oppose the inclusion of a restaurant within this development, which introduces a commercial use into what is currently a residential area. A restaurant will require a dedicated loading dock, which is proposed along Webster Street. This loading area would be directly adjacent to existing homes, including a one-story residence, and near other neighboring properties. The noise associated with deliveries, trash pickup, and ongoing service activity would have a direct and negative impact on nearby residents. In addition to increased traffic, this introduces an ongoing operational impact that is not consistent with the character of the neighborhood. Construction Impacts There are also important unanswered questions regarding construction logistics: Where will construction vehicles be staged? Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 23  Packet Pg. 60 of 489  Will workers be transported into the site, or will additional vehicles compete for already limited neighborhood parking? We have the RPP program in place in this neighborhood. How will disruption to residents be minimized during construction? Given the scale of this project, these impacts will be significant and should be clearly addressed. Housing Priorities While I strongly support increasing housing supply in Palo Alto, this project does not appear to address one of the City’s most critical needs: affordable housing. Increasing density without meaningfully contributing to affordability raises important questions about how this project aligns with broader community goals. For these reasons, I urge the City Council to deny the rezoning request as currently proposed. I would strongly urge the City to work with the developer on a more balanced alternative, one that meaningfully increases housing while remaining compatible with the surrounding neighborhood. A reduced-scale development, such as a project limited to approximately three stories with appropriate transitions to adjacent properties, would be far more consistent with the character of the area and would mitigate many of the concerns outlined above. Thank you for your time and consideration. Sincerely, Catherine Cohen Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 24  Packet Pg. 61 of 489  From:Doris Stoessel To:Sauls, Garrett Subject:Opposition to the Rezoning Proposal - 910 Webster Street Date:Monday, April 6, 2026 10:01:35 AM Dear members of the Palo Alto City Council: I am writing this e-mail to share my concerns regarding the proposed redevelopment of the Webster Oaks apartment complex located at 910 Webster Street. But first let me introduce myself: my name is Doris Stoessel, and I have owned 533 Channing Avenue (one of 24 units in the five building Channing Place Homeowners' Association complex located at 501-547 Channing Avenue) since June of 1982. I am opposed to redeveloping the Webster Oaks apartment complex for many reasons and am listing four major concerns highlighted below, each followed by a detailed explanation of that specific concern. 1. Too much additional traffic on four city streets: Channing Avenue, Addison Avenue, Homer Avenue, and Webster Street Let's face it: replacing the 24 unit Webster Oaks apartment complex with a 70 unit complex is going to triple the number of cars currently entering and exiting the complex. I don't have an exact number, but because the residents of our 24 unit Channing Place HOA have roughly 40 vehicles, I am going to assume that the current residents of the Webster Oaks apartment complex also have roughly 40 vehicles. And doing the math leads me to believe that a 70 unit complex would therefore have 120 vehicles. These four city streets were not designed to support an additional 80 (120-40) vehicles each day. 2. Additional traffic will be a hazard to pedestrians on Addison Avenue, Webster Street, and Channing Avenue Some residents on the 70-unit complex will connect each day from Middlefield to Webster via Homer Avenue and some will connect via Addison Avenue. There's a lot of slow-moving pedestrian traffic on Addison and Webster each morning and afternoon as children and parents walk to and from Addison Elementary School. And there's a lot of slow-moving pedestrian traffic on Webster and Channing as the residents of Channing House stroll around the neighborhood. Adding an additional 80 vehicles each day to this area can only lead to tragic accidents. 3. More (speeding) traffic on Channing Avenue Channing Avenue is a major connector for Palo Alto residents who live between Alma and Middlefield, and in my opinion, there's already too much traffic on this two lane city street. There are at least five stop signs along Channing at its western end, but there are no stop signs between Waverley and Middlefield, and drivers speed up along these three blocks despite the 25 mph speed limit. Fourteen of the 24 units in the Channing Place HOA complex enter/exit the complex via a narrow driveway separating our units from Channing House, and near- accidents occur too frequently as we pull onto Channing Avenue at a low speed. Adding up to an additional 80 vehicles each day to this area can only lead to accidents as we try to exit our complex. Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 25  Packet Pg. 62 of 489  4. Lack of sufficient overnight parking spots on Webster Street and Channing Avenue The 24-unit Channing Place HOA complex includes garages for its residents, but due to the small size of these garages, the residents have to park roughly 16 of their 40 vehicles on the street each night. By my estimate, the residents of the proposed 70 unit complex would end up having to park 50 (120-70) vehicles on the street each night, but there just aren't 50 parking spaces available. They will end up parking on residential streets south of Addison or forcing us to have to park overnight on residential streets of Addison. In summary, the proposed complex at 910 Webster Street is too much large for our neighborhood and our city streets. Please do not approve it. Thank you for your time and consideration. Sincerely, ...Doris A. Stoessel Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 26  Packet Pg. 63 of 489  From:Alfred To:Sauls, Garrett Subject:Regarding proposed condominium project at Webster Oaks Date:Friday, April 3, 2026 4:42:53 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Mr. Sauls: I reside on the corner of Cowper St and Channing Ave. in Palo Alto. I have lived here for over 36 years. After our brief phone conversation I have elected to submit my comments to you through this email. Please add my comments to the presentation to the City Council when they convene on April 20th, 2026. In response to the proposed Webster Oaks condominium project I am opposed to the proposed condominium project for the following reasons: There have been no six story structures permitted or built in the Professorville neighborhood in this century. A project of this magnitude would be out of scale with the rest of the residential area and would set a precedent for additional large scale residential development in this neighborhood. The area where the proposed condominium project is already congested with vehicle traffic, including delivery trucks, because both the Channing House and Addison Elementary School which are nearly adjacent to the proposed project. The disturbance and disruption, both during the construction and in the operation of this large condominium project would severely impact the daily life of the seniors living at the Channing House. Thank you for your time and consideration, Alfred J. Mandel 915 Cowper St. Palo Alto This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 27  Packet Pg. 64 of 489  From:mountain view To:Sauls, Garrett Subject:Webster Oaks apartment building project Date:Sunday, April 5, 2026 1:27:36 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Hello Admins, I am writing to formally express my disagreement with the proposed building project currently under consideration. While I understand the intent to support development and growth, I would like to elaborate on several specific concerns regarding the proposed building project: 1. Parking and Traffic Safety: Street parking in this area is already severely constrained, with occupancy rates exceeding 95% on most days. Given the proximity to Addison Elementary School, additional residential units would further intensify congestion. This will make student drop-off and pick-up significantly more difficult and could increase safety risks for children due to heavier traffic and reduced visibility. 2. Impact on School Capacity: Many families choose to live in this neighborhood because of the quality of the local public schools. Increasing the number of housing units may lead to a rise in student enrollment that exceeds the current capacity of nearby schools, potentially affecting class sizes, resources, and the overall quality of education in the community. 3. Safety Considerations: Taller, denser buildings near an elementary school may introduce additional safety and security concerns. It is important that any development near schools carefully assess potential risks and ensure appropriate measures are in place to protect students and staff. I believe that these factors have not been fully addressed and warrant more careful evaluation before any decisions are finalized. I respectfully urge the relevant authorities to reconsider or further review the proposal, taking into account community feedback and long-term consequences. I appreciate your time and attention to this matter and hope that my concerns will be given due consideration. Sincerely, VM This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 28  Packet Pg. 65 of 489  From:Robert Ord To:Sauls, Garrett Subject:Webster Oaks Proposal Date:Sunday, April 5, 2026 5:41:13 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. To Garrett Sauls, I live at 940 Webster Street two doors down from the Webster Oaks Apartments. I strongly oppose any changes to current zoning ordinances that would allow the newly proposed 70 units to be built at the Webster Oaks property. Parking is already a highly congested problem on our street!!! Sincerely, Robert Ord Property owner Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 29  Packet Pg. 66 of 489  From:victor greene To:Sauls, Garrett Subject:Re: Application # 26PLN-00026 Date:Tuesday, April 7, 2026 2:40:08 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Re: Application # 26PLN-00026 Palo Alto City Council Prescreening Hearing April 20, 2026 Attention: Project Planner Garrett Sauls I am Victor Greene. I am the homeowner at 581 Addison Avenue, Palo Alto, CA. The current property at 910 Webster Street, commonly known as the Webster Oaks apartment building, contains 20 living units in a two story structure. I am concerned about the proposal to rezone the site at 910 Webster Street to a planned community and redevelop the parcel with a new residential condominium building. The current zoning district is RM-20. The proposed rezoning is to zone the district as a PHZ district. A PHZ district is wholly disproportionate to the existing community. The surrounding homes and multifamily structures such as apartment houses and condominium structures are no more than two stories in height. The existing structures are in conformity with the prevailing neighborhood aesthetics. The Webster Oaks apartment building sits on the corner of Webster and Channing streets. Channing House, a building directly across on the opposite corner, is zoned PC-8659. Channing house was erected in the early 1960s and is zoned as a community building for elderly people to receive and enjoy lifetime care. Channing House is a benefit to our community. Not so with the proposal to rezone 910 Webster Street. The disparate impact of a PHZ structure that may rise to anywhere from eighty-one to ninety-two feet in height would overwhelm the residents our community who live in no more than two story high homes. The proposed condominium project of six stories in height would negatively impact its neighbors. I and my neighbors do not live downtown where high rise structures are consistent with downtown Palo Alto. We reside in a charming old neighborhood in what began as cottages adjacent to Stanford University. Our small lots and diminutive homes of old Palo Alto remain a tribute to the beauty and charm of our city. I urge the City Council to prevail upon the proposer of the project submitted in Application # 26PLN-00026 to limit the project to RN-20 zoning with no more than twenty units and a structure no higher than two stories. Respectfully submitted, Victor Greene This message needs your attention You've never replied to this person. Mark Safe Report Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 30  Packet Pg. 67 of 489  From:Sophia Tyra To:Sauls, Garrett Cc:ROY TYRA Subject:Proposed Development at Channing & Webster Date:Thursday, April 9, 2026 10:35:31 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Hello Garrett, I am a homeowner at 519 Channing Avenue. It was brought to my attention by our HOA that a developer has submitted a preliminary application for a high rise housing development at the corner of Channing and Webster, which is across the street from where I live. I would like to express my deep concerns for this proposed development. 1) Our zone is residential and although we’re in the downtown, the height and scale of surrounding buildings 3 stories or less. What makes me love my neighborhood is the “homey” feel, with open air views and daylight and trees for homeowners and pedestrians. A high rise development is not conducive to the current look and feel of the neighborhood nor does it fit the vibe of a Palo Alto residential neighborhood. It will cast shadows on surrounding homes and block critical views. 2) If the developer is relying on Channing House as a justifiable precedent for high rise buildings in this neighborhood, they are surely wrong. I live next to Channing House (adjacent to their loading dock side). Not only is that building disproportionally taller than all homes in the surrounding area, CH has proven to be a terrible neighbor to all of us. Between noisy delivery trucks that deliver at all hours day/night, street parking congestion and smoking and littering by their staff, we are all fed up with CH and we don’t want to see a similar development (size/scale) in our neighborhood. 3) Over the last 8-10 years, traffic on Channing Avenue has increased so much so that’s it’s become a main thoroughfare from Alma to Middlefield. There’s public buses, FedEx/UPS/Amazon trucks and countless delivery cars such as Door Dash along our street. This has resulted in drivers not abiding by the speed limit and/or driving the wrong way on a one way street. It’s natural to assume that this new development will add more congestion and traffic concerns with its occupants. A traffic study is necessary. There is a pedestrian crosswalk at Channing and Webster but it doesn’t deter speeders. Young families and children need to tread carefully on these streets to get to/from Addison Elementary. A traffic light intersection should be instalked and I hope that the developer provides an underground parking garage for the tenants. There is a lack of street parking as it stands currently. This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report Powered by Mimecast Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 31  Packet Pg. 68 of 489  I realize that I’m submitting my comments a bit late but I hope that you consider them in your findings. I would also like to attend any public hearings on this development. Thanks, Sophia Tyra Sent from the all new AOL app for iOS Item 4 Attachment D - Neighbor Comments        Item 4: Staff Report Pg. 32  Packet Pg. 69 of 489  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 Project Plans In order to reduce paper consumption, a limited number of hard copy project plans are provided to Council members for their review. The same plans are available to the public, at all hours of the day, via the following online resources. Directions to Review Project plans Online: 1. Go to: bit.ly/PApendingprojects 2. Scroll down to find “910 Webster Street” 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/910-Webster-St Item 4 Attachment E - Project Plans        Item 4: Staff Report Pg. 33  Packet Pg. 70 of 489  City Council Staff Report Report Type: CONSENT CALENDAR Lead Department: City Clerk Meeting Date: April 20, 2026 Report #:2604-6229 TITLE Approval of Minutes from April 6, 2026 Meeting RECOMMENDATION Staff recommends that the City Council review and approve the minutes. ATTACHMENTS Attachment A: April 6, 2026 Draft Action Minutes APPROVED BY: Mahealani Ah Yun, City Clerk Item 5 Item 5 Staff Report        Item 5: Staff Report Pg. 1  Packet Pg. 71 of 489  CITY COUNCIL DRAFT ACTION MINUTES Page 1 of 5 Regular Meeting April 6, 2026 The City Council of the City of Palo Alto met on this date in the Council Chambers and by virtual teleconference at 5:30 P.M. Present In Person: Burt, Lauing, Lu, Lythcott-Haims, Reckdahl, Stone, Veenker Present Remotely: Absent: Special Orders of the Day 1. Interview Candidate for Vacancies on the Planning & Transportation Commission; CEQA Status - Not a Project NO ACTION Agenda Changes, Additions and Deletions Public Comment Council Member Questions, Comments and Announcements Study Session 2. Discussion of Nonprofit Partnership Workplan Phase I Purpose and Improvements for FY 2027. CEQA Status – Not a project. NO ACTION Item 5 Attachment A - April 6, 2026 Draft Action Minutes        Item 5: Staff Report Pg. 2  Packet Pg. 72 of 489  DRAFT ACTION MINUTES Page 2 of 5 City Council Meeting Draft Action Minutes: 04/06/2026 3. San Antonio Road Area Plan Update and Council Feedback on Draft Land Use and Transportation Concepts and Alternatives. CEQA Status: Exempt under CEQA Guidelines Section 15262. NO ACTION Consent Calendar Councilmember Lythcott-Haims registered a no vote on Agenda Item Number 13. Councilmembers Stone and Burt registered a no vote on Agenda Item Number 5. MOTION: Vice Mayor Stone moved, seconded by Councilmember Lythcott-Haims to approve Agenda Item Numbers 4-13. MOTION PASSED ITEMS 4, 6-12: 7-0 MOTION PASSED ITEM 5: 5-2, Stone, Burt no MOTION PASSED ITEM 13: 6-1, Lythcott-Haims no 4. Approval of Minutes from March 16 and March 23, 2026 Meeting 5. Approval of Construction Contract No. C26196846 with FieldTurf USA, Inc. in an Amount Not-to-Exceed $878,919 for El Camino Park Turf Replacement PG-24000, Including Authorization to Execute Change Orders; and Amend the FY 2026 Budget Appropriation in the Capital Improvement Fund; CEQA status – categorically exempt under CEQA Guidelines sections 15301 (Existing Facilities) and 15302 (Replacement or Reconstruction). 6. Approval of General Services Contract No. C26194173 with Duke’s Root Control for a Total Not-to-Exceed Amount of $279,098 and a Three-Year Term and for Root Foaming Treatment Services; and Finding of California Environmental Quality Act (CEQA) Categorical Exemption pursuant to CEQA Guideline 15301, Maintenance of Existing Facilities 7. Approval of a Final Map for the Properties Located at 4335 and 4345 El Camino Real to Allow for a Condominium Subdivision to Create Eight Units on a 17,406-Square-Foot Parcel and to Create 21 Units on a 41,370-Square-Foot Parcel and the Naming of Three Private Streets Associated With the Development (25PLN-00160). CEQA Status: Exempt pursuant to CEQA Guidelines Section 15332 (In-fill Development). Zoning District: CS (Service Commercial). Item 5 Attachment A - April 6, 2026 Draft Action Minutes        Item 5: Staff Report Pg. 3  Packet Pg. 73 of 489  DRAFT ACTION MINUTES Page 3 of 5 City Council Meeting Draft Action Minutes: 04/06/2026 8. Approval of Contract Amendment Number 2 to Contract Number C21177635B with Ingram Library Services in the amount of $664,000 for Print Materials and Services for a new not-to-exceed (NTE) of $1,119,000 and to extend the contract term to June 30, 2028, Contract Amendment Number 2 to Contract Number C21177635C with Midwest Tape in the amount of $360,000 for Media and Digital Materials and Services for a new NTE of $1,113,000 and to extend the contract term to June 30, 2028, and Contract Amendment Number 1 to Contract Number C25190507 with OverDrive in the amount of $200,000 for Digital Materials and Services for a new NTE of $400,000 and to extend the contract term to June 30, 2028; CEQA Status – Not a Project. 9. Approval of Amendment Number 2 to Contract Number S20178516 with Hohbach- Lewin Inc. to Increase Compensation by $10,000, Revising the Amount Not-to-Exceed to $70,000 and Extend the Contract Term Through March 30, 2029, for On-Call Structural Engineering Services for Public Art Installations; CEQA Status – exempt under regulation 15061(b)(3). 10. QUASI-JUDICIAL. 530 Barron Avenue [25PLN-00021]: Appeal of Director’s Decision to Deny an Individual Review Application to Allow Partial Deconstruction of an Existing 924-Square-Foot Single-Story Residence and to Allow the Construction of a New 2,528- Square-Foot Two Story Single-Family Residence with Attached One-Car Garage, 303- Square-Foot Junior Accessory Dwelling Unit and 497-Square-Foot of Existing House Converted to Detached Accessory Dwelling Unit. CEQA Status: Exempt from the Provisions of CEQA in Accordance with CEQA Guidelines Section 15303. Zoning District: R-1 (Single-Family Residential). 11. SECOND READING: Ordinance of the Council of the City of Palo Alto Amending Chapter 18.70 (Nonconforming Uses and Noncomplying Facilities) of the Palo Alto Municipal Code to Allow De Minimis Exceptions (FIRST READING: March 9, 2026; PASSED: 7-0) 12. SECOND READING: Ordinance of the Council of Authorizing Work in the Baylands Related to the Adjacent Development at 2100-2400 Geng Road (24-PLN-00356) (FIRST READING: March 16, 2026; PASSED 7-0) 13. SECOND READING: Ordinance of the Council of the City of Palo Alto Amending Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto Municipal Code to Adopt Bird Friendly Design Standards (FIRST READING: March 16, 2026; PASSED: 5-2, Lu, Lythcott-Haims no) City Manager Comments Ed Shikada, City Manager Item 5 Attachment A - April 6, 2026 Draft Action Minutes        Item 5: Staff Report Pg. 4  Packet Pg. 74 of 489  DRAFT ACTION MINUTES Page 4 of 5 City Council Meeting Draft Action Minutes: 04/06/2026 Action Items AA1. Approval of Selection of and Employment Agreement with James Reifschneider as the Chief of Police at an Annual Salary of $363,584; CEQA Status – Not a Project New Item Added MOTION: Mayor Veenker moved, seconded by Vice Mayor Stone to confirm the City Manager’s selection of James Reifschneider as Police Chief and approve his employment agreement (Attachment A). MOTION PASSED: 7-0 14. Approval of FY 2026-2027 Human Relations Commission, Parks and Recreation Commission, Public Art Commission, and Stormwater Management Oversight Committee Work Plans; CEQA Status - not a project NO ACTION 15. Adoption of Recommendations by the Policy & Services Committee Implementing Changes to Meeting Procedures Related to Teleconferencing, Remote Public Participation, Translation and Interpretation Assistance, and Expanded Public Outreach; CEQA Status – Not a Project. Agenda Item Number 15 was not heard and was deferred to a date uncertain. 16. Approval of City Council Values (as Recommended by Policy & Services Committee), 2026 Objectives, Ad Hoc Purpose Statements, and Committee Workplans (Continued from 3/9/2026 - On March 9, 2026, the Council Received Presentations and Public Testimony; the Item Will be Continued to April 6 for further Council Deliberation and Action - No Public Testimony Will be Heard on April 6.) Item Removed Off Agenda Agenda Item Number 16 was removed off the agenda and not heard. Adjournment: The meeting was adjourned at 11:02 P.M. Item 5 Attachment A - April 6, 2026 Draft Action Minutes        Item 5: Staff Report Pg. 5  Packet Pg. 75 of 489  DRAFT ACTION MINUTES Page 5 of 5 City Council Meeting Draft Action Minutes: 04/06/2026 ATTEST: APPROVED: ____________________ ____________________ City Clerk Mayor NOTE: Action minutes are prepared in accordance with Palo Alto Municipal Code (PAMC) 2.04.160(a) and (b). Summary minutes (sense) are prepared in accordance with PAMC Section 2.04.160(c). Beginning in January 2018, in accordance with Ordinance No. 5423, the City Council found action minutes and the video/audio recordings of Council proceedings to be the official records of both Council and committee proceedings. These recordings are available on the City’s website. Item 5 Attachment A - April 6, 2026 Draft Action Minutes        Item 5: Staff Report Pg. 6  Packet Pg. 76 of 489  CITY COUNCIL Staff Report From: City Manager Report Type: CONSENT CALENDAR Lead Department: Planning and Development Services Meeting Date: April 20, 2026 Report #: 2603-6092 TITLE Adopt a Resolution Authorizing the Director of Planning and Development Services to Make Minor Modifications to the 2023-2031 Housing Element Site Inventory. CEQA Status: The City Council adopted a Revised Addendum to the Comprehensive Plan Final Environmental Impact Report on December 18, 2023, that, in conjunction with the Comprehensive Plan Final EIR, fully analyzes the impacts of the 6th Cycle Housing Element, including minor modifications to the site inventory. RECOMMENDATION Staff recommends that the City Council adopt a resolution to authorize the Director of Planning and Development Services to make modifications to the 2023-2031 Housing Element site inventory that are consistent with the adopted Housing Element. BACKGROUND On April 15, 2024,1 a joint meeting of the Planning and Transportation Commission and the City Council was held, and the City Council adopted a resolution adopting a revised 2023-2031 Housing Element. As part of its action to adopt the Revised Housing Element, the City Council directed and authorized the Director of Planning and Development Services to make any non- substantive changes or amendments to the Housing Element requested by the Department of Housing and Community Development (HCD) and to take all other actions necessary to achieve certification. Over the following months, the Director engaged with HCD and made several minor changes to the adopted Housing Element, including changes to the site inventory. The City’s Housing Element was certified by HCD on August 20, 2024.2 1https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82774&dbid=0&repo=PaloAlto&searchid=a9993a9 6-367c-4f66-877a-65b4c99ca3a2&cr=1 2https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development-services/housing- element/housing-element_2023_2031/palo-alto-housing-element.pdf Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 1  Packet Pg. 77 of 489  Regional Housing Need Allocation (RHNA) and Maintaining Adequate Sites Per State law requirements, the Housing Element contains information about the City’s housing needs, constraints to building housing, available housing sites, an explanation of City resources for supporting housing development, as well as goals, policies, and programs that will help address the City’s share of regional housing needs as identified by the Association of Bay Area Governments (ABAG). The City’s housing needs are quantified in the RHNA, which includes housing targets at all income levels. As shown in Table 1, the minimum RHNA requirement for Palo Alto in the 2023-31 planning period is 6,086 homes across four income levels. Table 1: City of Palo Alto 2023-31 RHNA Requirement Income Level Very Low Income Low Income Moderate Income Above Moderate Income Total Area Median Income (AMI)<50% AMI 50-80% of AMI 80-120% AMI >120% AMI Units 1,556 896 1,013 2,621 6,086 Program 1.1 Adequate Sites Program of the Housing Element, consistent with State law, requires the City to maintain a residential site inventory that is adequate to accommodate the City’s share of regional housing needs through the duration of planning period. Program 1.2 Site Inventory Monitoring Program, requires the City to identify additional housing inventory sites if there is a shortfall of adequate RHNA capacity for any income level.5 The City Council adopted a 2026 priority objective in March to identify and designate additional Housing Element site capacity to maintain RHNA compliance. This was identified in anticipation of estimated shortfalls occurring in 2026. The Housing Element site inventory6 includes estimated capacities and income levels based on the best available information at the time of adoption. It is normal for the site inventory to require periodic updates over the course of an eight-year housing element cycle. The proposed resolution would allow the Planning Director to maintain the site inventory as a living document to respond to mid-cycle conditions and to ensure that the City’s site inventory remains compliant with state law. Updates to the site inventory may be required for a variety of reasons. As sites in the inventory develop, the actual number of units and income levels will vary based on the unique circumstances of each project and likely will not match the City’s projections. A recent example is the project at 2100-2400 Geng Road recently approved by the City Council on March 16, 5 Note: for purposes of determining adequate capacity in a site inventory, the RHNA requirements for very low- and low-income are combined. (See Gov. Code Section 65583.2(c)(3).) 6 https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development-services/housing- element/housing-element_2023_2031/appendix-d_site-inventory.pdf Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 2  Packet Pg. 78 of 489  2026. The site was identified with an estimated capacity of 175 moderate income units, but the actual project developed with 145 units, none of which are at the moderate income level (126 units are above-moderate income and 19 units are deed restricted for lower income households). This project created a deficit in the City’s moderate income RHNA category, requiring the City to identify new sites to meet the capacity within 180 days. New sites to accommodate the RHNA must be “suitable and available” for residential development and will be subject to the same rigorous analysis performed in 2023 and 2024. FISCAL/RESOURCE IMPACT Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 3  Packet Pg. 79 of 489  STAKEHOLDER ENGAGEMENT ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 4  Packet Pg. 80 of 489  ***NOT YET APPROVED*** 1 0160186_20260324_ay16 RESOLUTION NO. _____ A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PALO ALTO, AUTHORIZING THE DIRECTOR OF PLANNING AND DEVELOPMENT SERVICES TO UPDATE AND MAINTAIN THE SITE INVENTORY FOR THE CITY’S 2023-2031 HOUSING ELEMENT R E C I T A L S A.State Housing Element Law (Government Code Sections 65580 et seq.) requires that the City Council adopt a Housing Element for the eight-year period 2023-2031 to accommodate the City of Palo Alto (City) regional housing need allocation (RHNA) of 6,086 housing units, comprised of 1,556 very-low income units, 896 low-income units, 1,013 moderate-income units, and 2,621 above moderate- income units; and B.State Housing Element Law further requires the City to include in its Housing Element an inventory of land suitable for residential development and adequate to accommodate the RHNA (Site Inventory). The Site Inventory must include the number of units that can realistically be accommodated on each site and whether each site is adequate to accommodate lower income housing, moderate-income housing, or above moderate-income housing. C.On April 15, 2024, the City Council adopted Resolution No. 10155, making various findings, adopting a Revised 2023-2031 Housing Element, and authorizing the Director of Planning and Development Services to take further actions necessary to achieve certification of the Housing Element by the California Department of Housing and Community Development (HCD). D.On August 19, 2024, HCD found that the Revised 2023-2031 Housing Element, as further modified on July 17, 2024, was substantially compliant with state law. E.Program 1.1 of the Housing Element, Adequate Sites Program, requires the City to maintain a residential site inventory that is adequate to accommodate the City’s RHNA throughout the duration of the Housing Element planning period of 2023-2031. Program 1.2 of the Housing Element, Site Inventory Monitoring Program, requires the City to identify additional housing inventory sites if there is a shortfall of capacity in the Site Inventory to accommodate the RHNA for any income level. F.In addition, elements of Programs 1.1 and 1.4 of the Housing Element could require the City to identify additional sites for the Site Inventory in the event development on certain sites has not progressed in accordance with timelines specified in those Programs. G.Finally, the City may wish to modify the Site Inventory on the basis of developer interest in accessing increased development potential that is permitted for sites on the Site Inventory. H.Minor modifications to the Site Inventory do not require changes to the analysis or policies and programs contained in the Housing Element and do not constitute revision or amendment of the Housing Element, as those terms are used in State Housing Element Law. Modifications to maintain an adequate Site Inventory are generally reported to HCD solely by means of a Housing Element Annual Progress Report. Item 6 Attachment A - Draft Resolution        Item 6: Staff Report Pg. 5  Packet Pg. 81 of 489  ***NOT YET APPROVED*** 2 0160186_20260324_ay16 I. Pursuant to the provisions and requirements of CEQA and CEQA Guidelines Section 15164, the City as lead agency, prepared a Revised Addendum to the 2017 Comprehensive Plan Final EIR (the Addendum) to analyze the potential environmental impacts resulting from the Revised 2023-2031 Housing Element. This includes housing production to meet the RHNA development of the Site Inventory and implementation of Housing Element programs, including Programs 1.1, 1.2, and 1.4; and J. On November 13 and December 18, 2023, the City Council approved the Addendum and found that the Addendum, in conjunction with the 2017 Comprehensive Plan EIR adequately analyzed the environmental impacts of development under the Housing Element. NOW, THEREFORE, BE IT RESOLVED, that the City Council hereby finds that, based on substantial evidence in the record: 1.The Director of Planning and Development Services is hereby directed and authorized to modify the Site Inventory to maintain adequate sites to accommodate the RHNA, to implement the requirements of various Housing Element programs, and as the Director deems appropriate in response to developer interest. 2.The City Council finds that routine modifications to the Site Inventory are consistent with the intensity of development analyzed in the Addendum and are not anticipated to have additional environmental impact beyond what was analyzed in the Addendum and the 2017 Comprehensive Plan EIR. // // // // // // // // // // // Item 6 Attachment A - Draft Resolution        Item 6: Staff Report Pg. 6  Packet Pg. 82 of 489  ***NOT YET APPROVED*** 3 0160186_20260324_ay16 3.This Resolution shall become effective upon adoption by the City Council. INTRODUCED and PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: ____________________________ ____________________________ City Clerk Mayor APPROVED AS TO FORM: APPROVED: ____________________________ ____________________________ Assistant City Attorney City Manager ____________________________ Director of Planning and Development Services Item 6 Attachment A - Draft Resolution        Item 6: Staff Report Pg. 7  Packet Pg. 83 of 489  City Council Staff Report From: City Manager Report Type: CONSENT CALENDAR Lead Department: IT Department Meeting Date: April 20, 2026 Report #:2602-5980 TITLE Approval of Amendment Number 1 to Contract C23187554 with Vox Network Solutions to Increase Compensation by $212,819 and to Extend the Term to June 30, 2027, for Maintenance of the City’s Enterprise Phone System; CEQA Status – exempt under section 15061(b)(3). RECOMMENDATION Staff recommends that the City Council approve and authorize the City Manager or designee to execute Amendment No. 1 to Contract No. C23187554 with Vox Network Solutions (Attachment A) for an additional year for the maintenance of the City’s Enterprise Phone System and to increase compensation by $136,897 for basic services and $75,921 for additional services. This amendment results in a revised total contract not-to-exceed amount of $713,740. BACKGROUND The City’s enterprise phone system was replaced under a VOX contract following a 2012 RFP process after the prior system was no longer supported by the manufacturer. City Council approved replacing the City’s legacy phone system with a modern Avaya VoIP/hybrid system on June 6, 2012, and the new system was fully implemented in October 20131. After implementation, the City continued to procure ongoing maintenance and support from VOX Most recently, on June 19, 2023, City Council approved Contract no. C23187554 to upgrade the City’s phone system and provide a three-year support term using a National Cooperative Purchasing Alliance (NCPA) cooperative agreement2. Amendment No. 1 maintains service continuity by adding a one-year extension and increasing not-to-exceed authority to address additional, unforeseen licensing necessary to sustain the City’s phone system. 1 June 4, 2012 City Council Staff Report: https://www.cityofpaloalto.org/files/assets/public/v/1/from- archive/agendas-minutes-reports/reports/city-manager-reports-cmrs/2012/cmr-2760.pdf 2 June 19, 2023 City Council Staff Report: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82463&dbid=0&repo=PaloAlto&cr=1 Item 7 Item 7 Staff Report        Item 7: Staff Report Pg. 1  Packet Pg. 84 of 489  ANALYSIS Staff recommends extending services with VOX Network Solutions for one more year to maintain stable, uninterrupted support for the City’s enterprise phone system while the City completes a structured assessment of the best long-term direction (continued on-premises Avaya modernization vs. a cloud solution). The City’s current phone environment supports essential municipal operations and integrations, particularly those tied to public safety, call center reporting, payment-by-phone/IVR workflows, outage/emergency operations, call accounting/audit needs, and hybrid work which are not always supported “out of the box” by basic cloud phone offerings. The existing system is now antiquated and approaching the end of its vendor-supported lifecycle. The City anticipates replacing and modernizing the phone system in the next fiscal year. As authorized under PAMC section 2.30.360(j), the current contract was procured through NCPA cooperative agreement5, which is reduced pricing available to local government agencies and provides a compliant, efficient procurement path for this interim period. The one-year renewal provides the City time to: (1) assess the City’s current Avaya platform and remaining lifecycle needs, (2) evaluate cost and risk options to upgrade or optimize the City’s on-premises Avaya environment, and (3) competitively investigate leading industry providers for a cloud- based solution without introducing avoidable service disruption or emergency/after-hours support gaps during the evaluation period. The requested contingency will fund payment of an outstanding $30,383 invoice that could not be paid because additional services funds were exhausted and provide a 10% contingency for unforeseen licensing adjustments during the extension period. This will help maintain continuity of the City’s telecommunications systems during ongoing changes and transition planning. The costs are expected to occur in FY 2027. Funding for this one-year amendment will be included in the FY 2027 annual budget development process, subject to City Council approval consistent with how multi-year technology support contracts are funded in future years. The Information Technology Department (ITD) is supported through an internal service fund model. Approximately 49% of ITD’s costs are funded by the General Fund, with the remaining 51% supported by enterprise and special revenue funds. The services were coordinated with internal stakeholders and the service provider. 5 NCPA Cloud and On-Premise Communications Solutions Contract No. 01-125: https://www.omniapartners.com/suppliers/jenne/public-sector/contract-documents Item 7 Item 7 Staff Report        Item 7: Staff Report Pg. 2  Packet Pg. 85 of 489  ENVIRONMENTAL REVIEW The approval of this contract is exempt from review under the California Environmental Quality Act (CEQA) under CEQA Guidelines section 15061(b)(3).  ATTACHMENTS Attachment A: Amendment No. 1 to Contract No. C23187554 APPROVED BY: Darren Numoto, Chief Information Officer; Lisa Bolger, Assistant Director Information Technology/CTO Item 7 Item 7 Staff Report        Item 7: Staff Report Pg. 3  Packet Pg. 86 of 489  AMENDMENT NO. 1 TO CONTRACT NO. C23187554 BETWEEN THE CITY OF PALO ALTO AND VOX NETWORK SOLUTIONS, INC. This Amendment No. 1 (this “Amendment”) to Contract No. C23187554 (the “Contract” as defined below) is entered into as of April 20, 2026, by and between the CITY OF PALO ALTO, a California chartered municipal corporation (“CITY”), and VOX NETWORK SOLUTIONS, INC., a Delaware Corporation, located at 110 S. Hartford Avenue, Suite 2502, Tulsa, OK 74120 (“CONSULTANT”). CITY and CONSULTANT are referred to collectively as the “Parties” in this Amendment. R E C I T A L S A. The Contract (as defined below) was entered into by and between the Parties hereto for the provision of upgrading the communications environment to the latest release of software, that offers a more secure communication platform, as detailed therein. B. The Parties now wish to amend the Contract in order to (1) extend the term end date from June 18, 2026 to June 30, 2027, (2) increase the not to exceed compensation by Two Hundred Twelve Thousand Eight Hundred Eighteen Dollars and Seventy-Two Cents ($212,818.72) from Five Hundred Thousand Nine Hundred Twenty-One Dollars and Twenty-Seven Cents ($500,921.27) to Seven Hundred Thirteen Thousand Seven Hundred Thirty-Nine Dollars and Ninety-Nine Cents ($713,739.99), and (3) update the scope, as detailed herein. NOW, THEREFORE, in consideration of the covenants, terms, conditions, and provisions of this Amendment, the Parties agree: SECTION 1. Definitions. The following definitions shall apply to this Amendment: a. Contract. The term “Contract” shall mean Contract No. C23187554 between CONSULTANT and CITY, dated June 19, 2023. b. Other Terms. Capitalized terms used and not defined in this Amendment shall have the meanings assigned to such terms in the Contract. SECTION 2. Section 2 “TERM” of the Contract is hereby amended to read as follows: “The term of this Agreement shall be from the date of its full execution through June 30, 2027 unless terminated earlier pursuant to Section 19 (Termination) of this Agreement.” Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 4  Packet Pg. 87 of 489  SECTION 3. Section 4 “NOT TO EXCEED COMPENSATION” of the Contract is hereby amended to read as follows: “The compensation to be paid to CONSULTANT for performance of the Services shall be based on the compensation structure detailed in Exhibit C, entitled “COMPENSATION,” including any reimbursable expenses specified therein, and the maximum total compensation shall not exceed Five Hundred Ninety-Two Thousand Two Hundred Eighty Dollars and Forty-Seven Cents ($592,280.47). The hourly schedule of rates, if applicable, is set out in Exhibit C-1, entitled “SCHEDULE OF RATES.” Any work performed or expenses incurred for which payment would result in a total exceeding the maximum compensation set forth in this Section 4 shall be at no cost to the CITY. Optional Additional Services Provision (This provision applies only if checked and a not- to-exceed compensation amount for Additional Services is allocated below under this Section 4.) In addition to the not-to-exceed compensation specified above, CITY has set aside the not- to-exceed compensation amount of One Hundred Twenty-One Thousand Four Hundred Fifty-Nine Dollars and Fifty-Two Cents ($121,459.52) for the performance of Additional Services (as defined below). The total compensation for performance of the Services, Additional Services and any reimbursable expenses specified in Exhibit C, shall not exceed Seven Hundred Thirteen Thousand Seven Hundred Thirty-Nine Dollars and Ninety-Nine Cents ($713,739.99), as detailed in Exhibit C. “Additional Services” means any work that is determined by CITY to be necessary for the proper completion of the Project, but which is not included within the Scope of Services described at Exhibit A. CITY may elect to, but is not required to, authorize Additional Services up to the maximum amount of compensation set forth for Additional Services in this Section 4. CONSULTANT shall provide Additional Services only by advanced, written authorization from CITY as detailed in this Section. Additional Services, if any, shall be authorized by CITY with a Task Order assigned and authorized by CITY’s Project Manager, as identified in Section 13 (Project Management). Each Task Order shall be in substantially the same form as Exhibit A-1, entitled “PROFESSIONAL SERVICES TASK ORDER”. Each Task Order shall contain a specific scope of services, schedule of performance and maximum compensation amount, in accordance with the provisions of this Agreement. Compensation for Additional Services shall be specified by CITY in the Task Order, based on whichever is lowest: the compensation structure set forth in Exhibit C, the hourly rates set forth in Exhibit C-1, or a negotiated lump sum. To accept a Task Order, CONSULTANT shall sign the Task Order and return it to CITY’s Project Manager within the time specified by the Project Manager, and upon authorization by CITY (defined as counter-signature by the CITY Project Manager), the fully executed Task Order shall become part of this Agreement. The cumulative total compensation to CONSULTANT for Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 5  Packet Pg. 88 of 489  all Task Orders authorized under this Agreement shall not exceed the amount of compensation set forth for Additional Services in this Section 4. CONSULTANT shall only be compensated for Additional Services performed under an authorized Task Order and only up to the maximum amount of compensation set forth for Additional Services in this Section 4. Performance of and payment for any Additional Services are subject to all requirements and restrictions in this Agreement.” SECTION 4. The following exhibit(s) to the Contract is/are hereby amended or added, as indicated below, to read as set forth in the attachment(s) to this Amendment, which is/are hereby incorporated in full into this Amendment and into the Contract by this reference: a. Exhibit “A” entitled “SCOPE OF SERVICES, AMENDMENT NO.1”, AMENDED, REPLACES PREVIOUS. b. Exhibit “C-1” entitled “SCHEDULE OF RATES, AMENDMENT NO.1”, AMENDED, REPLACES PREVIOUS. SECTION 5. Legal Effect. Except as modified by this Amendment, all other provisions of the Contract, including any exhibits thereto, shall remain in full force and effect. SECTION 6. Incorporation of Recitals. The recitals set forth above are terms of this Amendment and are fully incorporated herein by this reference. (SIGNATURE BLOCK FOLLOWS ON THE NEXT PAGE.) Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 6  Packet Pg. 89 of 489  SIGNATURES OF THE PARTIES IN WITNESS WHEREOF, the Parties have by their duly authorized representatives executed this Amendment effective as of the date first above written. CITY OF PALO ALTO City Manager APPROVED AS TO FORM: City Attorney or designee VOX NETWORK SOLUTIONS, INC. Officer 1 By: Name: Title: Officer 2 By: Name: Attachments: EXHIBIT “A” ENTITILED “SCOPE OF SERVICES, AMENDMENT NO.1”, AMENDED, REPLACES PREVIOUS EXHIBIT “C-1” ENTITILED “SCHEDULE OF RATES, AMENDMENT NO.1”, AMENDED, REPLACES PREVIOUS Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Sr Vice President Klaus Hillmann Evan Jones Chief Customer Officer Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 7  Packet Pg. 90 of 489  EXHIBIT A SCOPE OF SERVICES, AMENDMENT NO.1 AMENDED, REPLACES PREVIOUS CONSULTANT shall provide the Services detailed in this Exhibit A, entitled “SCOPE OF SERVICES”. CITY agrees to purchase and CONSULTANT agrees to provide Signature Support (“Services”) according to the terms of this Amendment No. 1. Waterfield Signature Support (Services) is an Information Technology Infrastructure Library (ITIL) based service consisting of the monitoring, troubleshooting, device and service management (incident, change, problem, MACD), and reporting of the CITY’s Managed Infrastructure. REQUIREMENT OF MANUFACTURER SUPPORT CONTRACT Access to manufacturer escalation support and access to patches and software for the covered systems is contingent upon purchase and maintenance of a Manufacturer Support Contract. If no manufacturer support exists or when equipment is deemed unsupportable by the manufacturer, or it is deemed not serviceable due to lack of replacement part availability, Waterfield support will be best effort. Services Elements Summary The following tables summarize the service elements included in this Waterfield Signature Support offer: Service Element Included Patch Management Certificate Management 3rd Party Case Management Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 8  Packet Pg. 91 of 489  Covered Assets Covered Qty Hardware Replacement Location : 3638486 CITY OF PALO ALTO- CITY HALL & PD, 250 HAMILTON AVE, PALO ALTO, CA, US, 94301 - City Hall & PD ASP130 P5 SRVR 1 ASP110 SRVR - ASBCE 2 LSP 1 G450 GTWY 2 N/A COMMUNICATION MGR - SIMPLEX/DUPLEX 1 Virtual ADS 1 Virtual SAL 1 Virtual SYSTEM MGR 1 Virtual SESSION MGR 1 Virtual AADS 1 Virtual BREEZE PRESENCE SERVER 1 Virtual AES 1 Virtual AVAYAMESSAGING R11 1 Virtual AVAYAMESSAGING - Consolidated Server 1 Virtual Center ASP130 P3 SRVR 1 G450 GTWY 1 LSP - S8300 1 COMMUNICATION MGR - ESS 1 Virtual SESSION MGR 1 Virtual SESSION MGR - Resiliency 1 Virtual IX MESSAGING 1 Virtual G430 GTWY 1 N/A S8300E SERVER 1 N/A G430 GTWY 1 N/A S8300E SERVER 1 N/A GTWY G430 GTWY 1 N/A G430 GTWY 1 N/A G430 GTWY 1 N/A Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 9  Packet Pg. 92 of 489  Location : 5367316 Children’s Library – 1275 Harriet St. Palo Alto, CA 94301 - Children's Library G430 GTWY 1 N/A Location : 5367317 Art Center – 1213 Newell Rd. Palo Alto, CA 94303 - Art Center Remote G430 GTWY 1 N/A Location : 5367318 Cubberly Ctr – 4000 Middlefield Rd. Palo Alto, CA 94303 - Cubberly Center G430 GTWY 1 N/A Location : 5367320 Fire Station 1 – 301 Alma St. Palo Alto, CA 94301 - Fire Station 1 G430 GTWY 1 N/A Location : 5367321 Fire Station 2 – 2675 Hanover St. Palo Alto, CA 94304 - Fire Station 2 G430 GTWY 1 N/A Location : 5367324 Junior Museum – 1451 Middlefield Rd. Palo Alto, CA 94301 - Junior Museum G430 GTWY 1 N/A Location : 5367326 Water Quality – 2501 Embarcadero Way Palo Alto, CA 94303 - Water Quality G430 GTWY 1 N/A Location : 5367329 Utilities Engineering Office – 1007 Elwell Ct. Palo Alto, CA 94303 - Utilities Eng. Office G430 GTWY 1 N/A Location : 51758172 Fire Station 3 – 2501 Embarcadero Way Palo Alto, CA 94303 - Fire Station 3 G430 GTWY 1 N/A Location : 51485177 Fire Station 4 – 3600 Middlefield Rd. Palo Alto, CA 94301 - Fire Station 4 G430 GTWY 1 N/A Location : 51485178 Fire Station 5 – 600 Arastradero Rd. Palo Alto, CA 94301 - Fire Station 5 G430 GTWY 1 N/A Location : 5367323 Fire Station 6 – 711 Serra St, Stanford, CA 94305 - Fire Station 6 G430 GTWY 1 N/A Hardware Replacement Legend: A = Manufacturer parts replacement NBD B = Manufacturer parts replacement 24x7x4 C = Manufacturer parts Replacement 8x5x4 D = Manufacturer parts replacement and onsite dispatch NBD E = Manufacturer parts replacement and onsite dispatch 24x7x4 F = Manufacturer parts replacement and onsite dispatch 8x5x4 N/A = Not Applicable INTEGRATED APPLICATIONS NOT COVERED If present, for applications that have an integration to covered assets listed above but that are not supported by Waterfield directly; Waterfield will support integration points within the covered assets only, far end applications to be supported by CITY or CITY’s vendor. 24x7x365 Service Desk • Waterfield will provide 24x7 system support for the solution environment. This includes access to Waterfield’s 24x7 Service Desk. All incidents will be responded to and managed according to Waterfield’s ticketing system. Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 10  Packet Pg. 93 of 489  • Waterfield will document procedures for communicating issues and accessing support. • CITY will be able to open and track tickets via the Waterfield Support Line (phone), the Waterfield Collaboration Portal (web), and email. Event Management Waterfield will monitor for Events on all Managed Assets listed above. Waterfield Responsibilities • Detect that an Event has occurred by monitoring syslog, SNMP trap messages, KPIs, and/or Threshold Crossing Alerts from Managed Assets. • Implement Event correlation and filtering through Event Management policies when an Event occurs. CITY Responsibilities • Provide access and make configuration changes required for Waterfield to receive messages from the Managed Assets. • Participate in mitigating and remediating events generated by CITY action or resulting from CITY-owned infrastructure elements. Incident Management Waterfield will remotely identify, troubleshoot, and restore normal operational functionality if an Incident is detected in a Managed Asset. Waterfield Responsibilities • Create tickets from detected or reported Events, where required. • Manage Incidents by classifying, prioritizing, troubleshooting, and restoring normal operation. • Escalation to the primary telephony OEM is included in Signature Support. Any other OEM or third-party escalations are supported only under the Enhanced Signature Support offering for 3rd Party Vendor Management. • Assign and reassess Incident priorities in accordance with Waterfield process and policy as defined in the Waterfield Service Management Governance addendum. • Notify relevant parties about Incidents, keeping the parties updated through Incident closure, per communication protocols established at onboarding (preferred CITY contacts, escalation points, etc.). • Provide Incident reports pertaining to the Managed Assets via the Waterfield Management Portal. CITY Responsibilities • Provide the means for Waterfield to access, troubleshoot, and resolve Managed Assets. Primary remote access for Waterfield will be via the Waterfield Monitoring Server. • Provide details about support contracts and other documentation/authorization required to facilitate Incident resolution. • Contact Waterfield if the CITY believes an Incident is in progress or has occurred. • Perform Waterfield- or third-party-recommended changes to Managed Assets or third-party Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 11  Packet Pg. 94 of 489  hardware, software, or services, if outside of the scope of Services Management. • Provide Waterfield with updates to CITY-initiated actions related to the Incident(s). Please note: Incident Tickets will be placed on “hold” for any period of time Waterfield is delayed in receiving required information from the CITY, the End User, or applicable third-party service providers. Hardware Replacement (Parts Coverage) Hardware replacement coverage listed in the Covered Assets table will be replaced under this contract via Waterfield parts coverage or Manufacturer Support parts coverage, as noted. Parts will be replaced on a Next Business Day basis if replacement is identified prior to 12:00 p.m. PST. Waterfield Technician Dispatch (Onsite Support) Based on evolving virtualization technologies and support models that have greatly reduced the need for onsite support, and to keep costs down for the CITY, technician dispatch for troubleshooting or replacement hardware installation, if required, will be provided on a Time and Materials basis only. • If replacement parts provided by the OEM or Waterfield require pre-staging or configuration prior to shipment to the CITY site, Waterfield will notify the CITY, stage the hardware at a Waterfield office location, and ship the hardware to the CITY site for CITY installation. • Upon request, onsite technician support will be provided on a best-effort basis with a Next Business Day target for Priority 1 and 2 Incidents, subject to hardware and resource availability and installation readiness. Onsite support will be billed on a Time and Materials basis or applied against contracted Bundled Hours (if purchased). Dispatch will be supported by a Waterfield resource or Waterfield-authorized contractor. • If Manufacturer onsite dispatch is purchased, dispatch is subject to the SLA of the purchased model per the Covered Assets table above. Problem Management Problem Management is the process of identifying the cause of an error in the supported solutions, usually reported as occurrences of related Incidents, and removing the causes of these errors permanently. Problem resolution and elimination of root cause often calls for the application of a change in the existing environments. Problem cases are created as necessary and worked by Waterfield staff in order to find the root cause for a single issue or a set of related issues and apply a permanent fix. Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 12  Packet Pg. 95 of 489  Change Management Change Management is the process of recording and managing the planned deployment of alterations to CITY environments, processes, and documentation. Waterfield will utilize the CITY’s documented Change Management process, if available. Otherwise, Waterfield will utilize its own system-enforced Change Management process to complete any change needed as the result of an Incident or Problem ticket. If required by documented CITY change procedures, Waterfield will prepare and provide a Method of Procedure (MOP) document in Waterfield’s standard format outlining the details, timing, and impacts of the change for CITY change-approval processing. If Waterfield is required to participate in CITY Change Advisory Board (CAB) meetings or utilize custom formats or processes for MOP development, additional charges may apply. Waterfield is not accountable for Changes made by CITY staff outside of the agreed-upon, documented Change Process. Waterfield will manage the deployment of technical changes to the Managed Assets (e.g., configuration changes) in the CITY’s environment as a result of a change activity. Change types supported by Change Management are Emergency, Normal, and Standard Changes. Waterfield Responsibilities • Manage the lifecycle of Change Management Requests, as required, resulting from an Incident, Problem, Service Request, as otherwise mutually agreed to in writing, or as required in accordance with the Change Management Process. • Coordinate, provide governance, and execute changes to Managed Assets, using commercially reasonable efforts to minimize any adverse impacts of those changes to the CITY’s environment. • Validate and prioritize Change Requests based on urgency. • Manage the end-to-end lifecycle of Change Requests. • Provide notifications of change request start and completion for CITY-impacting changes. • Work with the CITY to identify and approve Standard Changes. • As part of the CITY’s CAB process, discuss with the CITY any changes to Monitored Assets that may result from Changes approved with respect to the Managed Assets. • Perform pre- and post-change Health Checks. CITY Responsibilities • Provide written documentation to Waterfield at onboarding, or as modified throughout the contract term, defining any custom Change Policies or processes that must be adhered to by Waterfield. • Submit Requests for Change (RFCs) for Waterfield Managed Assets as Service Requests via the Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 13  Packet Pg. 96 of 489  Portal, Smart Bonding, or the CITY ITSM. • Submit Requests for Change (RFCs) for CITY Managed Assets as Changes via the Portal, Smart Bonding, or the CITY ITSM. • Inform Waterfield of CITY scheduling, communicating, and executing of changes or CITY- performed additions or modifications to the supported environment. • Provide Waterfield access to CITY CAB meetings and facilitate communication between Waterfield and the CITY’s CAB. • Confirm and maintain scheduled windows for change activities. • Determine and mitigate any impacts to the Monitored Assets or out-of-scope devices as a result of a change to the Managed Assets. • Review and approve (within 48 hours or less) Waterfield-initiated Changes to Managed Assets via Waterfield’s Service Portal. WATERFIELD Service Portal Waterfield will provide a web-based Portal that provides CITY reports and information related to the Services. The Waterfield Management Portal will be the primary means of communication on all cases between the Waterfield Service Team and the CITY. Waterfield Responsibilities • Implement and make available to the CITY a Portal for the Service. • Provide the capability to open, update, and review cases, changes, etc. • Provide the capability to view reports. CITY Responsibilities • Provide end user profiles for Portal access in accordance with relevant industry practice. • Review and update (as needed) Incidents and Change Requests. Bundled Hours – 6 Hours Annual Allotment Upon contract activation and at the anniversary date of each subsequent year of a multi-year contract, the CITY’s services account will be credited with the specified annual hours of Waterfield Services to be used at the CITY’s discretion. Additional hours beyond the included/bundled hours will be charged at the contracted rate below. Bundled hours allotment and rate are covered in the Program Fees section below. All work requested under Bundled Hours is facilitated, scheduled, and coordinated by the Waterfield support team, and all hours spent by all roles engaged in the planning and execution of requested work are accrued against the Bundled Hours. Utilization of hours is tracked and reported to the CITY on a monthly basis or available upon request. Bundled hours are intended to be used within the contract year and do not roll over to subsequent years. Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 14  Packet Pg. 97 of 489  Service Requests (Move, Add, Change and Delete – MACD) Typical uses for these hours include transactional programming requests generally related to specific user additions, removals, or changes and not holistic or scoped changes as outlined above. Waterfield maintains flexibility in working with the CITY on the utilization of Bundled Hours; however, they are intended for use primarily for MACD, defined as follows: • Requests are made via a ticket in the Waterfield Portal or via email to the Waterfield Service Desk, and fulfilled by Waterfield with communications occurring within Waterfield’s ticketing system. • MACD is defined as not requiring multiple resources or coordination with external vendors or parties, can be completed in less than two (2) hours per engagement, and does not require Project Management or Coordination. • Waterfield will utilize a proven change control process for managing changes requested under this program. • Complex requests requiring PMO management, third-party support coordination, multiple phases, or that support net-new functionality, integrations, or capabilities will be quoted as new project work through the Waterfield account team. SEVERITY DEFINITIONS AND RESPONSE SLA: LEVEL DEFINITION SERVICE LEVEL AGREEMENT Priority 1 Service interruption affecting whole site or network, mission critical server or service, or critical application on a Within one (1) hour Priority 2 Service interruption affecting small number of users, or service degradation affecting many users Within four (4) hours Priority 3 Service interruption affecting a single user, or service; degradation affecting Within one (1) business day Priority 4 Informational & General requests, Within one (1) week CITY acknowledges that incidents caused by system hardware or software may require third- party manufacturer involvement. Waterfield is not liable for system hardware or software failures or delays in receiving system software bug fixes, patches, maintenance releases, upgrades, or new version Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 15  Packet Pg. 98 of 489  EXHIBIT C-1 SCHEDUL OF RATES, AMENDMENT NO.1 AMENDED, REPLACES PREVIOUS CONSULTANT’S schedule of rates is as follows: Previously Paid Base for Year 1-3: $455,383.27 Previously Paid Additional Services Year 1-3: $45,538.33 Total Previously Paid Base and Additional Services Year 1-3: $500,921.60 Amendment #1: Year #4 Base: $136,897.20 Additional Services Increased by: $75,921.19 Total for Amendment #1: $212,818.39 New Total Not to Exceed Compensation: $713,739.99 RATES AMENDED FOR YEAR 1-3 Paid: ($500,921.60) These amounts for June 19, 2023 – June 18, 2026 are fully paid. RATES ADDED FOR NEW ADDITIONAL TERM YEAR 4 Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 16  Packet Pg. 99 of 489  New Avaya Subscription | UC 12-Month and CC 15-Month Term Description Recurring Qty Ext. UC Subscription: July 1, 2026 - June 30, 2027 | 12 MONTH Functional Location : 5233711 CITY OF PALO ALTO, 3201 E BAYSHORE RD, PALO ALTO, CA, US, 94303 255851 SA ON-SITE 24X7 APPL MED SRV R2D 1YPP $1,425.60 1 $1,425.60 NCPA not to exceed: Monthly: - Annual: 230192 SA ON-SITE 24X7 CM MED GTWY 1YPP $1,150.04 1 $1,150.04 NCPA not to exceed: Monthly: Annual: 230042 SA ON-SITE 24X7 CM SM SRV 1YPP $759.05 1 $759.05 NCPA not to exceed: Monthly: Annual: 352508 SA PREF ASP 130 R5 ESXI R7.X 1YPP $387.65 1 $387.65 NCPA not to exceed: Monthly: Annual: 434846 UC ADVANCED LIC FIXED SUBS ADJ LP $0.00 1 $0.00 Functional Location : 5367282 CITY OF PALO ALTO- UCC, 3241 E BAYSHORE, PALO ALTO, CA, US, 94303 434846 UC ADVANCED LIC FIXED SUBS ADJ LP $0.00 1 $0.00 Functional Location : 3638486 CITY OF PALO ALTO- CITY HALL & PD, 250 HAMILTON AVE, PALO ALTO, CA, 256194 SA ON-SITE 24X7 APPL LG SRV R2D 1YPP $2,851.20 1 $2,851.20 NCPA not to exceed: Monthly: - Annual: 255851 SA ON-SITE 24X7 APPL MED SRV R2D 1YPP $1,425.60 2 $2,851.20 Description Recurring NCPA not to exceed: Monthly: $118.80 - Annual: $1,425.60 230042 SA ON-SITE 24X7 CM SM SRV 1YPP NCPA not to exceed: Monthly: $63.25 - Annual: $759.05 352502 SA PREF S8300E R10.X ESXI R7.X 1YPP Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 17  Packet Pg. 100 of 489  NCPA not to exceed: Monthly: $29.37 - Annual: $352.40 284959 SA PREF ADS SAL GTWY OVA 284961 SA PREF ADS SLA MON OVA 284960 UPG ADV ADS SAL GTWY OVA 284962 UPG ADV ADS SLA MON OVA 352508 SA PREF ASP 130 R5 ESXI R7.X 1YPP NCPA not to exceed: Monthly: $32.30 - Annual: $387.65 433926 AES DMCC ENTL LIC FXD SUBS ADJLP 418056 AES DMCC ENTL R10 RBA FXD SUBS 433924 AES BASIC TSAPI ENTL LIC FXD SUBS ADJLP 418054 AES BASIC TSAPI ENTL R10 RBA FXD SUBS 434845 UC ESSENTIALS LIC FIXED SUBS ADJ LP NCPA not to exceed: Monthly: $5.52 - Annual: $66.24 418132 UC ESSNTLS R10 RBA FXD SUBS 434846 UC ADVANCED LIC FIXED SUBS ADJ LP NCPA not to exceed: Monthly: $7.92 - Annual: $95.04 418133 UC ADV R10 RBA FXD SUBS CC Subscription: April 1, 2026 - June 30, 2027 | 15 MONTH Functional Location : 3638486 CITY OF PALO ALTO- CITY HALL & PD, 250 HAMILTON AVE, PALO ALTO, CA, 405787 CC ELITE VCE LIC FXD SUBS ADJLP NCPA not to exceed: Monthly: $57.02 - Annual: $684.24 – 15 Month: $855.30 Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 18  Packet Pg. 101 of 489  Avaya Subscription | UC 12-Month and CC 15-Month Term Description Recurring Qty Ext. 418118 CC ELITE R10 RBA FXD SUBS $0.00 28 $0.00 Annual Subtotal: $99,581.49 Signature Support | 12-Month: July 1, 2026 - June 30, 2027 Description Recurring Qty Ext. WTSSP45931 Signature Support - Avaya $29,950.00 1 $29,950.00 WT-SSP-AV-MS Signature Support - Avaya WT-SSP-AV-BH Signature Support - Avaya Bundled Hours 1 6 Annual Subtotal: $29,950.00 XIMA Software License ADD Description Price Qty Ext. Price X0016 Realtime Agent $245.97 3 $737.91 PR-XC-Standard Pro-rated Xima Care Support $0.20 170 $34.00 Subtotal: $771.91 XIMA: July 6, 2026 - June 30, 2027 Description Recurring Qty Ext. Serial: CITYOFPALOALTO370D373E2CC216BA7B XC-8x5-R [Renewal] Standard Xima Care Support Contract $944.00 1 $944.00 Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 19  Packet Pg. 102 of 489  XIMA: July 6, 2026 - June 30, 2027 Description Ext. This contract includes: Cancellations and Refunds In the event of a cancellation of a Service agreement with Xima, the Customer will forfeit all prepaid Annual Subtotal: $944.00 TelStrat: July 6, 2026 - June 30, 2027 Description Recurring Qty Ext. Serial Number: 162-MAINT-ENG- Maintenance - Record Perpetual License-Y4 REC-01 $78.00 8 $624.00 Serial Number: 162-MAINT-ENG- Maintenance - Record Perpetual License-Y4 REC-01 $62.40 42 $2,620.80 Annual Subtotal: $3,244.80 28 Agent Seat Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 20  Packet Pg. 103 of 489  Vers.: Aug. 5, 2019 Page 18 of 18 Professional Services - One-Time Charge Description Price Qty Ext. Price WTPSO45931 Subscription Conversion License Service - Remote Refresh During Brief OT Event $2,405.00 1 $2,405.00 Subtotal: $2,405.00 Summary Description Recurring One-Time Avaya Subscription | UC 12-Month and CC 15-Month Term $99,581.49 $0.00 Signature Support | 12-Month: July 1, 2026 - June 30, 2027 $29,950.00 $0.00 XIMA Software License ADD $0.00 $771.91 XIMA: July 6, 2026 - June 30, 2027 $944.00 $0.00 TelStrat: July 6, 2026 - June 30, 2027 $3,244.80 $0.00 Professional Services - One-Time Charge $0.00 $2,405.00 Subt $133,720.29 $3,176.91 $136,897.20 Docusign Envelope ID: 90B3ABDD-8B03-4453-917E-469F8D76241B Item 7 Attachment A - Amendment No. 1 to Contract No. C23187554        Item 7: Staff Report Pg. 21  Packet Pg. 104 of 489  City Council Staff Report From: City Manager Report Type: CONSENT CALENDAR Lead Department: City Manager Meeting Date: April 20, 2026 Report #:2602-6009 TITLE FIRST READ: Adopt an Entertainment Zone Ordinance to Establish an Entertainment Zone on California Avenue as Recommended by the Economic Development Ad Hoc Committee; CEQA status – Categorically Exempt. RECOMMENDATION The Ad Hoc Economic Development Committee and staff recommends that the City Council adopt an Entertainment Zone Ordinance to Establish an Entertainment Zone on California Avenue. BACKGROUND AND ANALYSIS During the March 18 Ad Hoc Economic Development Committee meeting1, the committee reviewed the recommendation presented by staff and unanimously voted the following motion2: Recommend the City Council adopt an ordinance adding Chapter 9.05 to the Palo Alto Municipal Code to establish and regulate an entertainment zone pursuant to Senate Bill 969 to allow for the sale of certain alcoholic beverages by licensed establishments for consumption outside in the public right of way on the car-free portion of California Avenue subject to a special event permit including Romona Street, and direct staff to implement the following changes: 1. Allow for ongoing activation of entertainment zone by allowing for ongoing permits from business owners 1 March 18th Economic Development Agenda: https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=19967 2 March 18th Economic Development Committee Action Minutes: https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=19968&compileOutputType =1 Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 1  Packet Pg. 105 of 489  2. Provide staff the flexibility to expand the entertainment zone to the closed portion of Ramona Street after outreach of Ramona Street merchants 3. Modify the special event permit if necessary to effectuate this direction The Economic Development Staff Report 2602-5984 5 provides additional context. The proposed recommendations are intended to support the Council’s priority to enhance business vibrancy efforts. This report implements a portion of the Committee’s recommendation to advance the Entertainment Zone Ordinance on Car-Free California Avenue. Staff will return to the full City Council to consider expanding permissive use to the downtown area, specifically Car-Free Ramona Street, as well as any needed modifications to permitting requirements. This approach supports California Avenue merchants in time for the World Cup and upcoming Cal Ave activations, while allowing additional outreach regarding Car-Free Ramona Street and further review of the Special Event permit. Due to the unanimous vote, the first reading of the ordinance has been provided on the consent calendar for approval. If approved on consent, the second reading would be taking place May 4, 2026, on the City Council’s consent calendar. The ordinance will become effective 30-days after the second reading, which means the entertainment zone may commence in early June. FISCAL/RESOURCE IMPACT Establishment of an Entertainment Zone requires the one-time administrative costs associated with ordinance and administrative guideline development. Staff will recommend that ongoing costs to support Entertainment Zone operation be recovered through permitting fees to the extent necessary. No additional funding is needed at this time. STAKEHOLDER ENGAGEMENT Economic Development staff met with representatives from the California Department of Alcoholic Beverage Control, County of Santa Clara Department of Public Health and the City of San Jose Office of Economic Development to gain a comprehensive understanding of how an entertainment zone operates. Staff met multiple times with California Avenue merchants to ensure the Zone supports California Avenue merchants. The proposed hours, boundary, and additional recommended requirements reflect coordination with the merchants. In addition, internal coordination took place with the Police Department to assess operational, and enforcement considerations specific to Palo Alto. Additional outreach with the Ramona Street stakeholders is forthcoming. 5 Economic Development Staff Report 2602-5984: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=86868&dbid=0&repo=PaloAlto Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 2  Packet Pg. 106 of 489  ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 3  Packet Pg. 107 of 489  NOT YET APPROVED 1 Ordinance No. ____ Ordinance of the Council of the City of Palo Alto Creating New PAMC Chapter 9.05 (Entertainment Zones) and Establishing an Entertainment Zone on a Portion of California Avenue The Council of the City of Palo Alto does ORDAIN as follows: SECTION 1. Findings and Declarations. The City Council finds and declares as follows: A. In 2025, the State of California authorized cities to create entertainment zones with the passage of SB 969 (2025), as codified in various sections of the Business and Professions Code (BPC). B. In compliance with BPC section 25692, City staff have notified and received feedback from the Palo Alto Police Department about (1) potential health and safety impacts that might be generated by the entertainment zone and strategies to mitigate those impacts; and (2) the zone’s proposed boundaries, days and hours of operation, types of alcoholic beverages permitted, and approved nonglass and nonmetal containers. C. The City Council now desires to adopt this ordinance to create new Chapter 9.05 in the Palo Alto Municipal Code (PAMC) to implement entertainment zones in Palo Alto. This ordinance will also establish one entertainment zone on the car-free section of California Avenue. SECTION 2. New Chapter 9.05 (Entertainment Zones) is hereby added to Title 9 (Public Peace, Morals, and Safety) of the Palo Alto Municipal Code to read as follows: 9.05.010 Purpose The purpose of this Chapter is to implement Senate Bill 969 (2025) as codified in various sections of the Business and Professions Code through the establishment and regulation of entertainment zones to allow the purchase of open container alcoholic beverages for consumption outside in common spaces such as plazas, public streets, sidewalks or public rights-of-way during certain hours. 9.05.020 Definitions. The definitions set forth in this Section shall govern the application and interpretation of this Chapter. "ABC" means the California Department of Alcoholic Beverage Control. "Entertainment Zone" has the meaning set forth in Section 23039.5 of the California Business and Professions Code, as may be amended; and their locations are described under PAMC Section 9.05.050. Item 8 Attachment A - Entertainment Zone Ordinance        Item 8: Staff Report Pg. 4  Packet Pg. 108 of 489  154_20260304_ts24 2 "Entertainment Zone Event" means an event that occurs within the boundaries of an Entertainment Zone in compliance with state law, local laws, and regulations, including this Chapter 9.05, and subject to the requirements of a special event permit issued by the City. 9.05.030 Entertainment zone requirements. (a) All persons and legal entities of any type (including businesses and non-profit organizations) sponsoring an Entertainment Zone Event, or selling alcoholic beverages at an Entertainment Zone Event shall comply with all applicable state and local laws and regulations, including: 1. All applicable ABC license and permitting requirements; 2. Sections 23357, 23358, 23396 of the California Business and Professions Code, as may be amended from time to time regulating licensed beer manufacturers, licensed winegrowers, and on-sale licensees, respectively; 3. All other laws governing the sale and consumption of alcoholic beverages; and 4. All permit requirements for special events issued by the City. (b) Open alcoholic beverages may only be consumed within an Entertainment Zone during an Entertainment Zone Event, subject to any other restrictions imposed by state or local law, regulations, and permits. (c) All open alcoholic beverages consumed during an Entertainment Zone Event may only be purchased from a premises located within the Entertainment Zone that is authorized under California Business and Professions Code Section 23357, 23358, 23396, as may be amended, to permit the consumers to leave the premises with open containers of alcoholic beverages for consumption off the premises, or an organization that is authorized by an ABC special event permit or license to make such sales within the Entertainment Zone. (d) All types of beer, wine, spirits, and other alcoholic beverages that are allowed for sale and consumption by the State of California are permitted within an Entertainment Zone, subject to any further restrictions imposed by regulations, license, or permit conditions. This subsection does not authorize any specific ABC licensee to sell or serve types of alcohol not permitted by their license. 9.05.040 Entertainment zone hours. Outdoor consumption of alcoholic beverages during an Entertainment Zone Event shall only occur between the hours of 12 noon and 10 p.m., inclusive, and on Sundays from 10 a.m. to 10 p.m., inclusive, subject to more restrictive days or times imposed by state or local law, regulations, or permits. 9.05.050 Entertainment zone locations. (a) Car-Free California Avenue. All plazas, pedestrian malls, public streets, sidewalks and public rights-of-way that are located on either side of California Avenue between El Camino Real and Birch Street are hereby designated as the California Avenue Entertainment Zone under Sections 23039.5 and 25690 of the California and Business and Professions Code. Item 8 Attachment A - Entertainment Zone Ordinance        Item 8: Staff Report Pg. 5  Packet Pg. 109 of 489  154_20260304_ts24 3 9.05.060 Entertainment zone implementation. (a) Within 90 days of the establishment or modification of an Entertainment Zone, the City’s Office of Economic Development, following consultation with the Police Department, shall provide the following information to ABC, pursuant to Section 25690 of the California Business and Professions Code: 1. A copy of the ordinance establishing or modifying the Entertainment Zone; 2. Information as may be necessary to identify the boundaries of the Entertainment Zone; 3. The days and hours of operation of the Entertainment Zone; 4. The types of alcoholic beverages permitted within the Entertainment Zone; and 5. The approved nonglass and nonmetal containers in which alcoholic beverages may be authorized. (b) The City Manager or designee is authorized to promulgate regulations under this Chapter 9.05. The regulations shall include the following requirements: 1. Establish a process or procedure to readily identify individuals purchasing or consuming alcoholic beverages within the Entertainment Zone as being 21 years of age or older; 2. Any person or organization seeking a special events permit shall comply with the insurance requirements applicable to that permit; and 3. Any additional requirements not otherwise imposed by state or local law, including but not limited to additional requirements for approved beverage containers, additional restrictions on hours and/or location of operation for the Entertainment Zone Events, and other time, place and manner restrictions. (c) Upon adoption or revision of the regulations, the Office of Economic Development shall transmit a copy of the regulations to ABC as applicable under ABC requirements. (d) Any holder of an ABC license or permit that wishes to allow customers to leave the premises with open containers of alcoholic beverages for consumption off the premises during an Entertainment Zone Event shall provide the City a copy of the notice provided to ABC under Section 23357, 23358, 23396, or any other applicable section of the California Business and Professions Code, as applicable, at the same time such notice is provided to ABC. (e) In compliance with Section 25692(b) of the California Business and Professions Code, the City Manager or designee shall review the operation of the entertainment zone every two years following the adoption of the entertainment zone to ensure that the entertainment zone is being maintained in a manner that protects the health and safety of the general public. This review shall be conducted in consultation with the Palo Alto Police Department and any reports produced during the review shall be made available to the Department upon request. SECTION 3. Section 9.04.010 of Chapter 9.04 (Alcoholic Beverages) of Title 9 (Public Peace, Morals, and Safety) of the Palo Alto Municipal Code is hereby amended to add subsection (c) to read as follows (new text in underline): Item 8 Attachment A - Entertainment Zone Ordinance        Item 8: Staff Report Pg. 6  Packet Pg. 110 of 489  154_20260304_ts24 4 9.04.010 Streets, sidewalks, highways, alleys - Consumption of alcoholic beverages prohibited. (a) It shall be unlawful for any person to consume any alcoholic beverage upon any street, sidewalk, highway or alley except as may be authorized by City Council. (b) Notwithstanding subsection (a) of this section, alcoholic beverages may be consumed in a city-owned or controlled right-of-way by patrons within legally permitted eating establishment seating areas in accordance with, and subject to a conditional use permit issued pursuant to § 18.76.010 of this code. (c) Notwithstanding subsection (a) of this section, alcoholic beverages may be consumed in a city-owned or controlled right-of-way when duly permitted within an Entertainment Zone and in full compliance with Chapter 9.05 (Entertainment Zones) and all applicable regulations, and permit and license conditions. SECTION 4. Severability. If any provision, clause, sentence or paragraph of this ordinance, or the application to any person or circumstances, shall be held invalid, such invalidity shall not affect the other provisions of this Ordinance which can be given effect without the invalid provision or application and, to this end, the provisions of this Ordinance are hereby declared to be severable. SECTION 5. Effective Date. This ordinance shall be effective on the 31st day after adoption. // // // // // Item 8 Attachment A - Entertainment Zone Ordinance        Item 8: Staff Report Pg. 7  Packet Pg. 111 of 489  154_20260304_ts24 5 SECTION 6. CEQA. The City Council finds and determines that this Ordinance is categorically exempt under CEQA regulation 15305 (minor alterations in land use limitations) and 15323 (normal operations of facilities for public gatherings). INTRODUCED: PASSED: AYES: NOES: ABSTENTIONS: ABSENT: ATTEST: ____________________________ ____________________________ City Clerk Mayor APPROVED AS TO FORM: APPROVED: ____________________________ ____________________________ Assistant City Attorney City Manager ____________________________ Economic Development Manager ____________________________ Chief of Police Item 8 Attachment A - Entertainment Zone Ordinance        Item 8: Staff Report Pg. 8  Packet Pg. 112 of 489  City Council Staff Report From: City Manager Report Type: CONSENT CALENDAR Lead Department: Utilities Meeting Date: April 20, 2026 Report #:2602-5891 TITLE Approval of Contract Amendment No. 3 to Contract S25190354 with Larratt Brothers Plumbing Inc. in the Amount of $950,000, for a Revised Total Not to Exceed $1,445,000 and to Extend the Contract Term for One Additional Year ending July 21, 2027, for the Residential Emergency Water Heater Replacement Pilot Program Within Electrification Programs; CEQA Status – Not a Project. RECOMMENDATION Staff recommends that City Council approve and authorize the City Manager or their designee to execute Amendment No. 3 (Attachment A) to Contract S25190354 with Larratt Brothers Plumbing Inc. for the Emergency Water Heater Replacement (REWHR) Pilot Program, increase the contract in an amount not-to-exceed $950,000, and amend Exhibit C to add one measure covering administrative fees and to extend the contract term by one additional year to a three- year term. This amendment results in a revised total contract not-to-exceed amount of $1,445,000. EXECUTIVE SUMMARY Staff is seeking approval for contract amendment number 3 to Contract S25190354 for the Single-Family Residential Emergency Water Heater Replacement (REWHR) Pilot Program to contribute to the success of the Advanced Heat Pump Water Heater (HPWH) Pilot Program in replacing a total of 1,000 gas water heaters. Staff is requesting to extend the REWHR contract term by one additional year, increase the contract by an additional $950,000, and update Exhibit C to continue offering the REWHR Pilot Program with a minor program improvement. Staff will offset the amendment amount by disencumbering $950,000 from the previous vendor under contract No. C23181953A1 for the Advanced HPWH Pilot Program. Emergency water heater replacements have accounted for more of the HPWH replacements than initially 1 Contract S25190354 with Larratt Brothers Plumbing http://www.paloalto.gov/files/assets/public/v/1/utilities/linking-documents/s25190354-larrett-brothers- plumbing.pdf Item 9 Item 9 Staff Report        Item 9: Staff Report Pg. 1  Packet Pg. 113 of 489  expected, the program receives high customer satisfaction and is helping the City achieve the goal of replacing 1,000 gas water heaters with HPWHs. The current two-year contract is set to end on July 31, 2026. This amendment will extend the contract term to July 31, 2027This amount is part of the originally budgeted HPWH program approved by Council on October 3, 2022, funded through the Electric Utility’s Electrification Reserve and Gas Cap and Trade revenues (see Staff Report 14720 and Council Resolution 10075, and Resolution 10076).3 BACKGROUND 4 The 2023-2025 S/CAP Work Plan included work item 2.1 D, which called for the launch of a HPWH pilot to achieve the replacement of 1,000 gas water heaters with HPWHs. The “Advanced HPWH Pilot Program” was launched in March 20235. It includes rebates for residents who hire their own contractors and a Full-Service program for those who want the City to take care of the whole process, as well as the addition of the REWHR program in September 2024. As of January 2025, 743 installations had been completed across the City’s Rebate, Full-Service, and REWHR programs, with 195, 489, and 59 installations completed under each program, respectively since the Advanced HPWH Pilot Program was adopted in October 2022. The REWHR program was created to facilitate the swift replacement of gas water heaters with heat pump alternatives, addressing the gap left by the Full Service HPWH program, which was not designed for emergency installations. The 2026- 2027 S/CAP Work Plan was approved by City Council on March 2, 2026, continuing the residential electrification programs.6 3 Staff Report 14720, October 3, 2022: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82036&dbid=0&repo=PaloAlto&searchid=595cfc83- 730f-4a8e-acb8-2a711994f8de&cr=1 ; Council https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=61564&dbid=0&repo=PaloAlto Resolution of the Council of the City of Palo Alto Adopting Design Guidelines for an Advanced Heat Pump Water Heater Pilot Program to Further the City’s Sustainability and Climate Action Plan Goals https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=61564&dbid=0&repo=PaloAlto; and Council https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=61565&dbid=0&repo=PaloAlto Resolution of the Council of the City of Palo Alto Establishing an Electrification Reserve and Amending the Electric Utility Reserves Management Practices https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=61565&dbid=0&repo=PaloAlto 4 2023-2025 S/CAP Work Plan https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82107&dbid=0&repo=PaloAlto&searchid=2893517 6-b25e-40fe-8f67-106930338767&cr=1 5 On October 3, 2022, City Council approved the contract with Synergy Companies, which includes, among other tasks, the administration of an Advanced Heat Pump Water Heater Pilot (https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=81976&dbid=0&repo=PaloAlto) 6 2026-2027 S/CAP Work Plan https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=85324&dbid=0&repo=PaloAlto&searchid=b2427f35 -4f5e-45e1-a2a0-3fac0fad9e95 Item 9 Item 9 Staff Report        Item 9: Staff Report Pg. 2  Packet Pg. 114 of 489  The REWHR program has received high customer satisfaction, achieving a score of 9 out of 10. Installations have been successfully completed within two business days, demonstrating Larratt Bros Plumbing Inc.'s commitment to providing excellent customer service. Their unique customer service tool, called Plunjr, allows homeowners to enter the program quickly and obtain an assessment and quote for a new HPWH. 11 in October 2024 to accommodate an increased budget of $410,000. Amendment No. 212 made a clerical correction to add an optional Additional Services Provision. In November 2025, a Task Order was executed that allowed Larratt Bros Plumbing Inc. to temporarily serve the Full Service HPWH program during the transition away from the City’s contract with Synergy Companies (contract No. C23181953A), to a new Turnkey Home Electrification Program developed with Franklin Energy Services (contract No. C25193676) called “Electrify My Home.”13 Due to increased incentives from the State’s TECH Clean California program, heightened demand to complete installations prior to the expiration of Federal Tax Credits, and higher participation from the Full Service HPWH program, more funds were utilized at a faster pace than anticipated. The City will receive an estimated $170,000 in reimbursement from the State for the TECH funds disbursed. Amendment number 3 will ensure the REWHR program can continue for one additional year, serving an estimated 150 more HPWH installations (generated from an estimated 300 home assessments). This extension will facilitate further installations throughout Palo Alto, enhancing the transition from gas to heat pump water heaters under emergency circumstances. ANALYSIS 14 In such an emergency scenario, the task of switching from a gas water heater to an HPWH is often too complicated and takes too much time for the average homeowner to handle when they are focused on restoring hot water to their family. The REWHR Pilot Program is designed to serve the many homes experiencing water heater failures that require rapid action, with a goal to restore hot water to customers within two business 11 Amendment No. 1 with Larratt Brothers Plumbing https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83038&dbid=0&repo=PaloAlto&searchid=b540650 7-db33-4482-b4e6-fa48c313aef6 12 Contract S25190354 Amendment No. 2 with Larratt Brothers Plumbing http://www.paloalto.gov/files/assets/public/v/1/utilities/linking-documents/s25190354a2-larratt-bros- amendment-no-2.pdf 13 https://www.paloalto.gov/Departments/Utilities/Electrification/Electrify-My-Home 14 New Buildings Institute, 2022. https://newbuildings.org/scaling-up-market-transformation-for-heat-pump- water-heaters/ Item 9 Item 9 Staff Report        Item 9: Staff Report Pg. 3  Packet Pg. 115 of 489  days while helping the homeowner switch from a gas water heater to an HPWH. Customers could opt to pay a premium covering work outside of standard business hours if faster service is desired. FISCAL/RESOURCE IMPACT 19 19 For the Full Service HPWH Program, City Council approved $1.25 million from Gas Cap and Trade Revenues, $4.5 million from Electrification Reserve (funded by the electric utility’s Electric Special Projects Reserve) discussed at the September 27, 2022 Council meeting, see https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=81997&dbid=0&repo=PaloAlto&searchid=67b1ec98 -3e85-4ae9-868b-c7513b8ff43e&cr=1; and approved at the October 3, 2022 Council meeting, see Item 9 Item 9 Staff Report        Item 9: Staff Report Pg. 4  Packet Pg. 116 of 489  The HPWHs installed through the REWHR Pilot will count towards the goal of 1,000 HPWHs in Palo Alto. The additional funds requested here come from disencumbering $950,000 from the previous vendor under contract No. C23181953A for the Advanced HPWH Pilot Program. Program promotion and outreach will be funded through the climate action outreach budget established in the FY 2026 Adopted Budget. Funding in subsequent fiscal years is subject to Council’s approval of annual budget appropriations.11 STAKEHOLDER ENGAGEMENT Feedback collected from program participants and collaboration with strategic partners have been instrumental in shaping this program. Engagement with stakeholders like Silicon Valley Clean Energy and others ensures program alignment and efficacy. ENVIRONMENTAL REVIEW Council’s approval of the attached agreement described in this staff report does not meet the definition of a project under the California Environmental Quality Act (CEQA), pursuant to the California Public Resources Code Section 21065, because it is not an activity that will cause a direct physical change in the environment. In the alternative, Council’s approval of this agreement is exempt from review under CEQA Guidelines Section 15302, as replacement of existing facilities, and Section 15308, as an action taken for the protection of the environment. ATTACHMENTS Attachment A: Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing APPROVED BY: Alan Kurotori, Director Utilities Staff: Linda Grand, Sustainability Programs Administrator https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=82036&dbid=0&repo=PaloAlto&searchid=1d57fc3a -c6b9-46a6-aa21-ab6b0fe2a000 Item 9 Item 9 Staff Report        Item 9: Staff Report Pg. 5  Packet Pg. 117 of 489  Vers.: Aug. 5, 2019 Page 1 of 11 AMENDMENT NO. 3 TO CONTRACT NO. S25190354 BETWEEN THE CITY OF PALO ALTO AND LARRATT BROS PLUMBING INC. This Amendment No. 3 (this “Amendment”) to Contract No. S25190354 (the “Contract” as defined below) is entered into as of March 16, 2026, and between the CITY OF PALO ALTO, a California chartered municipal corporation (“CITY”), and LARRATT BROS PLUMBING INC., a California corporation, located at 88 Elmira Street, San Francisco, CA 94124 (“CONSULTANT”). CITY and CONSULTANT are referred to collectively as the “Parties” in this Amendment. R E C I T A L S A. The Contract (as defined below) was entered into by and between the Parties hereto for the provision of providing Emergency Water Heater Replacement Services (the “Project”) to customers in single family homes in connection with the Project, as detailed therein. B. The Parties now wish to amend the Contract in order to increase compensation by Nine Hundred Fifty Thousand Dollars ($950,000) from Four Hundred Niney-Five Thousand dollars ($495,000) to a new total not to exceed One Million, Four Hundred Forty-Five Thousand Dollars ($1,445,000), and to extend the term until July 21, 2027, as detailed herein. NOW, THEREFORE, in consideration of the covenants, terms, conditions, and provisions of this Amendment, the Parties agree: SECTION 1. Definitions. The following definitions shall apply to this Amendment: a. Contract. The term “Contract” shall mean Contract No. S25190354 between CONSULTANT and CITY, dated August 1, 2024, as amended by: Amendment No. 1, dated October 7, 2024 Amendment No. 2, dated November 20, 2024 b. Other Terms. Capitalized terms used and not defined in this Amendment shall have the meanings assigned to such terms in the Contract. SECTION 2. Section 2 “TERM” of the Contract is hereby amended to read as follows: “SECTION 2. TERM. The term of this Agreement shall be from the date of its full execution through July 21, 2027, unless terminated earlier pursuant to Section 19 (Termination) of this Agreement.” Docusign Envelope ID: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 6  Packet Pg. 118 of 489  Vers.: Aug. 5, 2019 Page 2 of 11 SECTION 3. Section 4 “NOT TO EXCEED COMPENSATION” of the Contract is hereby amended to read as follows: “SECTION 4. NOT TO EXCEED COMPENSATION. The compensation to be paid to CONSULTANT for performance of the Services shall be based on the compensation structure detailed in Exhibit C, entitled “COMPENSATION,” including any reimbursable expenses specified therein, and the maximum total compensation shall not exceed One Million Three Hundred Thousand Five Hundred Dollars ($1,300,500). The hourly schedule of rates, if applicable, is set out in Exhibit C-1, entitled “SCHEDULE OF RATES.” Any work performed or expenses incurred for which payment would result in a total exceeding the maximum compensation set forth in this Section 4 shall be at no cost to the CITY. Optional Additional Services Provision (This provision applies only if checked and a not-to-exceed compensation amount for Additional Services is allocated below under this Section 4.) In addition to the not-to-exceed compensation specified above, CITY has set aside the not-to-exceed compensation amount of One Hundred Forty-Four Thousand Five Hundred Dollars ($144,500) for the performance of Additional Services (as defined below). The total compensation for performance of the Services, Additional Services and any reimbursable expenses specified in Exhibit C, shall not exceed One Million, Four Hundred Forty-Five Thousand Dollars ($1,445,000), as detailed in Exhibit C. SECTION 4. The following exhibit(s) to the Contract is/are hereby amended or added, as indicated below, to read as set forth in the attachment(s) to this Amendment, which is/are hereby incorporated in full into this Amendment and into the Contract by this reference: a. Exhibit “B” entitled “SCHEDULE OF PERFORMANCE ”, AMENDED, REPLACES PREVIOUS. b. Exhibit “C-1” entitled “SCHEDULE OF RATES”, AMENDED, REPLACES PREVIOUS. SECTION 5. Legal Effect. Except as modified by this Amendment, all other provisions of the Contract, including any exhibits thereto, shall remain in full force and effect. SECTION 6. Incorporation of Recitals. The recitals set forth above are terms of this Amendment and are fully incorporated herein by this reference. (SIGNATURE BLOCK FOLLOWS ON THE NEXT PAGE.) Docusign Envelope ID: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 7  Packet Pg. 119 of 489  Vers.: Aug. 5, 2019 Page 3 of 11 SIGNATURES OF THE PARTIES IN WITNESS WHEREOF, the Parties have by their duly authorized representatives executed this Amendment effective as of the date first above written. CITY OF PALO ALTO _____________________________ City Manager APPROVED AS TO FORM: _____________________________ City Attorney or designee LARRATT BROS PLUMBING, INC. Officer 1 By:______________________________ Name:___________________________ Title:____________________________ Officer 2 (Required for Corp. or LLC) By:______________________________ Name:___________________________ Title:____________________________ Attachments: Exhibit “B” entitled “SCHEDULE OF PERFORMANCE”, AMENDED, REPLACES PREVIOUS. Exhibit “C-1” entitled “SCHEDULE OF RATES”, AMENDED, REPLACES PREVIOUS. Docusign Envelope ID: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 President Aaron Gianni Andrew Geller Field Director Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 8  Packet Pg. 120 of 489  Vers.: Aug. 5, 2019 Page 4 of 11 EXHIBIT B SCHEDULE OF PERFORMANCE AMENDMENT NO. 3, AMENDED, REPLACES PERVIOUS CONSULTANT shall perform the Services so as to complete each milestone within the number of days/weeks specified below. The time to complete each milestone may be increased or decreased by mutual written agreement of the Project Managers for CONSULTANT and CITY so long as all work is completed within the term of the Agreement. CONSULTANT shall provide a detailed schedule of work consistent with the schedule below within 2 weeks of receipt of the notice to proceed (“NTP”) from the CITY. Milestones Completion Number of Days/Weeks (as Task 1.1 HPWH ER Kick-off Task 1.2 Develop HPWH ER Pilot Documents Task 1.2.1 Develop Program Policies and Procedures Manual Task 1.2.2 Develop Customer Site Assessment Report and Estimate Task 1.2.3 Develop Customer Site Assessment Agreement Task 1.2.4 Develop Program Participation Agreement Task 1.2.5 Develop Customer Feedback Forms Task 1.2.6 Develop Program Report Template Task 1.2.7 Develop Program Invoice Template Task 1.3 Transmit Customer Information to CITY’s Program Tracking Database Task 1.4 Setup and testing of program invoice and rebate submission Task 1.5 Provide Eligible Measure List Updates Task 1.6 Enroll in State or Local Financing Programs 30 days Task 2 Program Implementation Task 2.1 Implement Marketing and Outreach Activities Task 2.2 Develop Customer Intake & hotline Task 2.3 Perform Customer Site Assessment and Deliver Customer Estimate Task 2.4 Execute Program Participation Agreement, Collect Customer Payments, and Enroll Customers in Financing Programs Task 2.5 Install Measures and Provide Post-Installation Quality Control Task 2.6 Provide Customer Service, Feedback and Issue Resolution Ongoing Task 3 Program Invoicing and Reporting Task 3.1 Data Management Task 3.2 Reporting Task 3.3 Invoicing Ongoing Docusign Envelope ID: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 9  Packet Pg. 121 of 489  Vers.: Aug. 5, 2019 Page 5 of 11 Task 4.1 Resolve Outstanding Jobs in Progress Task 4.2 Develop and Submit Program Report Ongoing Within 30 days Optional Schedule of Performance Provision for On-Call or Additional Services Agreements. (This provision only applies if checked and only applies to on-call agreements per Section 1 or agreements with Additional Services per Section 4.) The schedule of performance shall be as provided in the approved Task Order, as detailed in Section 1 (Scope of Services) in the case of on-call Services, or as detailed in Section 4 in the case of Additional Services, provided in all cases that the schedule of performance shall fall within the term as provided in Section 2 (Term) of this Agreement. Docusign Envelope ID: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 10  Packet Pg. 122 of 489  Vers.: Aug. 5, 2019 Page 6 of 11 EXHIBIT C-1 SCHEDULE OF RATES The figures set forth in this Exhibit C-1 include all of CONSULTANT’s costs to perform all of the Services listed in this Agreement that correspond to that Eligible Measure, including, without limitation, CONSULTANT’s administrative costs, marketing and outreach costs, implementation (materials and labor) costs, Electrification Site Preparation Services, Electrification Labor Rates and Extended Parts and Labor Warranty costs. No additional fees or charges will be required of CITY or its customers for CONSULTANT to perform the Services listed in this Agreement. CONSULTANT’s schedule of rates is as follows: Eligible Measure Description of Measure Cost to Customer (not payable by City):* Installed cost per unit (incl equipment + Installed cost per unit (incl equipment + labor) ($) Heat pump water heater (80 gallon, 240V) - weekday properly dispose of the old water heater and platform, cap the gas line, install the drain pan, install the heat pump water heater and condensate draining per manufacturer’s instruction based on location, install new safety straps meeting code, install noise and vibration reduction components (flexible pipe connectors, rubber mat, rubber grommet at pipe-wall penetrations, rubber grommet where seismic strapping meets wall,) install expansion tank, complete job closure paperwork, repair and paint walls to original condition as required, standard one (1) year labor warranty, and manufacturer's product warranty. heater (65 gallon, 240V) - weekday heater (50 gallon, 240V) - weekday heater (80 gallon, 120V) - weekday heater (65 gallon, 120V) - weekday heater loaner - from loaner-reuse supply, properly Docusign Envelope ID: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 11  Packet Pg. 123 of 489  Vers.: Aug. 5, 2019 Page 7 of 11 replacing with HPWH at a later date, keep loaner equipment for future projects. The customer shall pay the $1800 at the time it is installed. The amount will be considered a “down payment” towards their electrification and noted on the final invoice as a credit Project Estimate - with phone/chat/emai all homes will receive an assessment and a Project Estimate - this row covers remote service (not in-person at the ) visit for assessment and project Estimate - normal weekday perform assessment and prepare a Project Estimate. Note that this charge is instead of, not in addition to the virtual assessment charge above. N/A $295 Permit Coordination, Optional use for inspectors to use Plunjr app, at the discretion of the City. $500 N/A Permit cost covered by the City. N/A $247, subjected to annual adjustment to Fee for any month with fewer than 15 site Non-standard Site Preparation and/or Installation Services costs for a HPWH installation Louver Vents into Install Condensate Temperature- Pressure Relief Docusign Envelope ID: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 12  Packet Pg. 124 of 489  Vers.: Aug. 5, 2019 Page 8 of 11 exterior away from foundation per building code Install Thermostatic hours will be estimated as part of the Project hours will be estimated as part of the Project Electrical services circuit breaker and up to 30 ft circuit between HPWH and run (per additional 50 replacement properly dispose of old equipment, replace with new panel including capability for future home electrification and EV readiness, include two additional reserve breaker spaces above and beyond electrification readiness, replace circuit breakers as required, repair and paint walls to original condition as required, standard one (1) year labor warranty, and manufacturer's product Materials - this work is highly variable in cost, and cannot be reduced to a single pre- determined price replacement / installation of old equipment, ensure home includes capability for future home electrification Docusign Envelope ID: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 13  Packet Pg. 125 of 489  Vers.: Aug. 5, 2019 Page 9 of 11 beyond electrification readiness, replace circuit breakers as required, repair and paint walls to original condition as required, standard one (1) year labor warranty, and manufacturer's product saver quad breaker (tandem breaker, install tandem breaker to maximize use of physical space in panel. Program Set Up Costs - up of meetings for Larratt Bros staff. Additional meeting time is noted in up of meetings for QuitCarbon staff. Additional meeting time is noted in Optional Additional Measures heater (80 gallon, 240V) - weeknight, weekend, holiday heater (65 gallon, 240V) - weeknight, weekend, holiday heater (50 gallon, 240V) - weeknight, weekend, holiday Docusign Envelope ID: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 14  Packet Pg. 126 of 489  Vers.: Aug. 5, 2019 Page 10 of 11 weeknight, weekend, holiday heater (65 gallon, 120V) - weeknight, weekend, holiday water heater loaner - weeknight, weekend, holiday Assessment & estimate - remote - weeknight, weekend, holiday staff, with the benefit of QuitCarbon virtual assessments - note that some homes will receive this remote project bid during non-weekday business hours visit for assessment and project estimate- weeknight, weekend, holiday hours - upcharge perform assessment and/or prepare a bid outside of normal business hours, this additional charge will apply. Note that this charge is instead of, not in addition to, the site visits during normal business hours that is noted in the first Rate - weeknight, weekend, holiday will be estimated as part of the Project Estimate phase. Rate - weeknight, weekend, holiday will be estimated as part of the Project Estimate phase. and labor Include 2 yr warranty from the date of installation Docusign Envelope ID: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 15  Packet Pg. 127 of 489  Vers.: Aug. 5, 2019 Page 11 of 11 place other than the garage or outside (ground level) closet shall be accessed with an additional cost. Protection of floors, walls, or other finishes shall be assessed on an individual basis and the cost will vary depending on the level of * Note that the Costs to the Customer detailed here are not payable by the City and are only included here to establish the agreed upon pricing to be charged by CONSULTANT to customers. Docusign Envelope ID: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 16  Packet Pg. 128 of 489  Certificate Of Completion Envelope Id: 2CA5A8B5-5391-45E8-89F8-6822631BE3C3 Status: Completed Subject: Complete with Docusign: S25190354 Amend 3 final approved rev 3.31.26.pdf Source Envelope: Document Pages: 11 Signatures: 2 Envelope Originator: Certificate Pages: 2 Initials: 0 Ann Marie Romero AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-08:00) Pacific Time (US & Canada) 250 Hamilton Ave Palo Alto , CA 94301 annmarie.romero@paloalto.gov IP Address: 2601:205:4a80:e Record Tracking Status: Original 3/31/2026 9:47:20 AM Holder: Ann Marie Romero annmarie.romero@paloalto.gov Location: DocuSign Security Appliance Status: Connected Pool: StateLocal Signer Events Signature Timestamp Aaron Gianni aaron@larrattbros.com President Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 73.189.115.94 Sent: 3/31/2026 9:49:21 AM Viewed: 3/31/2026 12:43:27 PM Signed: 3/31/2026 12:43:46 PM Electronic Record and Signature Disclosure: Not Offered via Docusign Andrew Geller ageller@larrattbros.com Field Director Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 2601:640:8e80:33ad:e8df:59de:ffee:6b10 Sent: 3/31/2026 12:43:48 PM Viewed: 3/31/2026 4:04:28 PM Signed: 3/31/2026 4:07:00 PM Electronic Record and Signature Disclosure: Not Offered via Docusign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Rachael Romero Rachael.Romero@paloalto.gov Administrative Associate II Copa Security Level: Email, Account Authentication (None) Sent: 3/31/2026 4:07:02 PM Viewed: 3/31/2026 4:37:23 PM Electronic Record and Signature Disclosure: Not Offered via Docusign Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 17  Packet Pg. 129 of 489  Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 3/31/2026 9:49:21 AM Certified Delivered Security Checked 3/31/2026 4:04:28 PM Signing Complete Security Checked 3/31/2026 4:07:00 PM Completed Security Checked 3/31/2026 4:07:02 PM Payment Events Status Timestamps Item 9 Attachment A - Contract S25190354 Amendment No. 3 with Larratt Brothers Plumbing        Item 9: Staff Report Pg. 18  Packet Pg. 130 of 489  CITY COUNCIL Staff Report From: City Manager Report Type: CONSENT CALENDAR Lead Department: Planning and Development Services Meeting Date: April 20, 2026 Report #: 2604-6210 TITLE 4075 El Camino Way [23PLN-00202]: Recommendation to Decline Adoption on Second Reading of an Ordinance Adopting an Amendment to a Planned Community Ordinance (PC-5116) to Allow for Modifications to an Existing 121-Unit Assisted Living and Memory Care Facility. First Reading Adoption was on March 16, 2026. CEQA Status: Exempt from the Provisions of the California Environmental Quality Act (CEQA) in Accordance with CEQA Guidelines Section 15301 (Modifications to Existing Facilities). RECOMMENDATION Staff recommends that the City Council: 1. Decline to adopt the second reading ordinance allowing the application to be withdrawn as requested by the applicant. BACKGROUND On March 16, 2026, the City Council held a public hearing and, after reducing the number of new units on the site from eleven to seven, approved the project and planned community ordinance on a 7-0 vote. On March 30, 2026, Planning and Development Services received written notice from the applicant's representative withdrawing the subject application. In light of the Council’s action reducing the scope of the project to seven units, the applicant is no longer interested in moving forward. In light of this request to withdraw the application, staff recommends that the City Council decline to adopt the attached ordinance on second reading. As an alternative to the staff recommendation, three councilmembers may pull this item from the consent calendar to schedule a hearing. An agendized hearing would afford the City Council an opportunity to reconsider its prior action. Item 10 Item 10 Staff Report        Item 10: Staff Report Pg. 1  Packet Pg. 131 of 489  Attached to this report is the draft planned community ordinance reflecting the City Council action from March 16, 2026. A link to the prior report and background information is available online.1 ATTACHMENTS APPROVED BY: 1 March 16, 2026, City Council staff report agenda item 13 is available online at: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=86819&dbid=0&repo=PaloAlto Item 10 Item 10 Staff Report        Item 10: Staff Report Pg. 2  Packet Pg. 132 of 489  *** NOT YET APPROVED *** 0160182_20260407_ay16 1 Ordinance No. ____ Ordinance of the Council of the City of Palo Alto Amending Section 18.08.040 of the Palo Alto Municipal Code (The Zoning Map) to Amend PC Planned Community Zone (PC-5116) to Allow an Addition to an Existing Senior Assisted Living Facility The Council of the City of Palo Alto ORDAINS as follows: SECTION 1. Findings and Declarations. The City Council finds and declares as follows: A. On March 21, 2011, the City Council adopted Ordinance No. 5116, creating PC Planned Community 5116. B. On August 9, 2023, Irwin Partner Architects on Behalf of Wellquest Living submitted an application for an Ordinance Amending Planned Community Zone District 5116 (PC-5116) to allow a 16-Unit addition and 172 square feet of support space to an existing 121-unit Assisted Living and Memory Care Facility (the “Project”) at 4041 and 4075 El Camino Way (the “Subject Property”). C. Following Staff Review, the Planning and Transportation Commission (“PTC”) reviewed the project on February 28, 2024 and June 12, 2024 and recommended the project to the Architectural Review Board. D. The Architectural Review Board reviewed the project on July 18, 2024 and October 17, 2024; and recommended approval of the project to the City Council. E. The PTC reviewed the project on December 11, 2024 and moved to advance the project to Council, recommending approval of only the seven units which do not face Wilkie Way and denial of the nine units and ground floor office space which faces towards the neighborhood. The motion also recommended returning the Transportation Demand Management plan to the PTC for approval, revising the Findings to reflect the PTC’s recommendation, and removing consideration of past public benefits from the PC Ordinance. F. The City Council reviewed the project on May 5, 2025 and May 27, 2025 and moved to refer the project back to the PTC with direction that the project be reduced to 11 to 13 units, eliminating third floor units facing Wilkie Way. G. The PTC reviewed the project again on September 24, 2025 and recommended approval of the project with additional revisions, including a reduction in the project scope to seven new units. H. Approval of the Planned Community Project would constitute a project under the provisions of the California Environmental Quality Act of 1970, together with related state and local implementation guidelines promulgated thereunder (“CEQA”). Item 10 Attachment A - Draft Planned Community Ordinance        Item 10: Staff Report Pg. 3  Packet Pg. 133 of 489  *** NOT YET APPROVED *** 0160182_20260407_ay16 2 I. The City is the Lead Agency pursuant to Public Resources Code section 21067 as it has the principal responsibility to approve and regulate the Planned Community Project. J. The City, in compliance with CEQA, determined the project to be Categorically Exempt from CEQA per Section 15301 of the CEQA Guidelines (Existing Facilities). K. The Council is the decision-making body for approval of the Planned Community Project. L. The site is so situated, and the use or uses proposed for the site are of such characteristics that the application of general districts or combining districts will not provide sufficient flexibility to allow the proposed development. Specifically, the project modifies an existing Planned Community Project (PC 5116) and includes 11 additional units, beyond the 121 units approved in ordinance 5116, and associated modifications to the development plan in accordance with this change. M. Development of the site under the provisions of the PC planned community district will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts, as set forth in Section 6 of this ordinance. N. The use or uses permitted, and the site development regulations applicable within the district are consistent with the Palo Alto Comprehensive plan, and compatible with existing and potential uses on adjoining sites or within the general vicinity. SECTION 2. Amendment of Zoning Map. Section 18.08.040 of the Palo Alto Municipal Code, the “Zoning Map,” is hereby amended by changing the zoning of the property formerly zoned as PC Planned Community Zone 5116 from PC Planned Community Zone 5116 to “PC Planned Community Zone _____”. SECTION 3. Project Description. The Project as a whole is described in the Development Plan titled “PALO ALTO COMMONS Wellquest Living” and uploaded to the Palo Alto Online Permitting Services Citizen Portal on October 16, 2025, and as modified by the City Council on March 16, 2026. Specifically, only units one through four and nine through eleven are approved; the other proposed new units depicted on the plans are not approved. The Development Plan and approved supplemental materials and conditions included as part of Ordinance 5116 and Ordinance 3775 are incorporated into this ordinance by reference. With respect to the Subject Property, the Project comprises the uses included in this Ordinance, depicted on the Development Plans as modified by the City Council, incorporated by reference, including the following components: (a) Modifications to an existing 121-unit assisted living and memory care facility, approved as part of PC Planned Community 5116. The additions would include construction of seven additional assisted living units (approximately 3,958 square feet). SECTION 4. Land Uses. (a) The following land uses shall be permitted: Item 10 Attachment A - Draft Planned Community Ordinance        Item 10: Staff Report Pg. 4  Packet Pg. 134 of 489  *** NOT YET APPROVED *** 0160182_20260407_ay16 3 1. Senior Housing; 2. Eating and Drinking Services for use by residents, employees, and their guests; 3. Personal Services for use by residents, employees, and their guests; 4. Retail Services for use by residents, employees, and their guests; 5. Recreational Facilities for use by residents, employees, and their guests; 6. Administrative Offices for administration of Palo Alto Commons; 7. Medical care for residents as is customarily associated with senior assisted living facilities; and 8. Accessory Uses. SECTION 5. Site Development Regulations and Development Schedule. (a) Development Standards: Development standards for the Subject Property shall be those conforming to the Development Plan. (b) Parking and Loading Requirements: The Owner shall provide parking and loading as set forth in the Development Plan and Parking Management Plan, entitled “Parking Study & Parking Management Plan for Palo Alto Commons at 4075 El Camino Way in Palo Alto, California,” uploaded to Accela on April 9, 2025. The existing 97 spaces on the property shall be maintained and the Owner shall implement all modifications to the Parking Management Plan required by the Record of Land Use Action for the Project (RLUA No. 2025-XX). (c) Modifications to the Development Plan, Land Uses and Site Development Regulations: Once the Project has been constructed consistent with the approved Development Plan, any modifications to the exterior design of the Development Plan or any new construction not specifically permitted by the Development Plan or the site development regulations contained in Section 5 (a) – (b) above shall require an amendment to this Planned Community zone. Any use not specifically permitted by this ordinance shall require an amendment to the PC ordinance. (d) Development Schedule: The Project is required to include a Development Schedule pursuant to PAMC §18.38.100. The approved Development Schedule is set forth in the Applicant Project Description Letter, and anticipates commencing in April 2025 and concluding in October 2026. Item 10 Attachment A - Draft Planned Community Ordinance        Item 10: Staff Report Pg. 5  Packet Pg. 135 of 489  *** NOT YET APPROVED *** 0160182_20260407_ay16 4 Construction of the project shall commence within two years of the effective date of this ordinance. Prior to expiration of this timeline, the Owner may seek a one year extension from the Director of Planning and Development Services. SECTION 6. Public Benefits. (a) Public Benefits: Development of the Project Site under the provisions of the PC Planned Community District will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts. The public benefit provided by the Project is providing a safe place for Palo Alto residents and other seniors to age and making improvements to the existing facility to expand and improve these services. (b) Monitoring of Conditions and Public Benefits: The Applicant shall be responsible for reimbursing the City for all costs incurred in connection with annual compliance inspections and any code enforcement–related activities associated with this approval that occur outside of the annual review process. Such reimbursement shall be provided either through the placement of a deposit or by payment on a time-and-materials basis, as determined by the Director of Planning and Development Services, in accordance with the Palo Alto Municipal Fee Schedule in effect at the time the costs are incurred. If conditions or benefits are found deficient by staff, the applicant shall correct such conditions in not more than 90 days from notice by the City. If correction is not made within the prescribed timeframe, the Director of Planning and Development Services will schedule review of the project before the Planning and Transportation Commission and Council to determine appropriate remedies, fines or other actions. SECTION 7. Environmental Review. The project would not result in a substantial expansion of the current use and is therefore eligible for a categorical exemption from CEQA under Section 15301 of the CEQA Guidelines (Existing Facilities). // // // // // // Item 10 Attachment A - Draft Planned Community Ordinance        Item 10: Staff Report Pg. 6  Packet Pg. 136 of 489  *** NOT YET APPROVED *** 0160182_20260407_ay16 5 SECTION 8. Effective Date. This ordinance shall be effective on the thirty-first day after the date of its adoption (second reading). INTRODUCED: PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: ____________________________ ____________________________ City Clerk Mayor APPROVED AS TO FORM: APPROVED: ____________________________ ____________________________ Assistant City Attorney City Manager ____________________________ Director of Planning and Development Services Item 10 Attachment A - Draft Planned Community Ordinance        Item 10: Staff Report Pg. 7  Packet Pg. 137 of 489  From:Charlene Kussner To:Raybould, Claire Cc:Steve Sandholtz; Stephen Reller; Daniel Bowman Subject:RE: 4075 el camino way, Withdrawal of Application 23PLN-00202, Amend PC-5116 Date:Monday, March 30, 2026 10:51:17 AM Attachments:image001.png image002.png image003.png CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Good morning Claire, please have this email be confirmation from the owner of 4075 El Camino Way, Palo Alto Commons, to withdraw the application PLN-00202 to amend PC-5116. The owner is no longer pursuing this entitlement and will not be building any additional units to Palo Alto Commons. Any conditions approved at City Council hearing dated 3.16.26 no longer apply. PC-5116 conditions remain in force, and we will continue to adhere to. Please let me know if this is sufficient, or additional information is required. Thanks to you and Emily for supporting this project. Charlene Kussner | V.P. of Development & Asset Management charlene@wqliving.com C: 951.757.2571 Corporate Office: 185 South State Street, Suite 1300, Salt Lake City, UT 84111 CA Office: Wellquest of Menifee Lakes, 29914 Antelope Road, Menifee CA 92586 “All that I have seen teaches me to trust the Creator for all I have not seen.” Ralph Waldo Emerson THIS MESSAGE CONTAINS CONFIDENTIAL INFORMATION AND IS INTENDED ONLY FOR THE INDIVIDUAL(S) NAMED. IF YOU ARE NOT THE NAMED ADDRESSEE(S) YOU SHOULD NOT DISSEMINATE, DISTRIBUTE OR COPY THIS E-MAIL. PLEASE NOTIFY THE SENDER IMMEDIATELY BY E-MAIL IF YOU HAVE RECEIVED THIS E-MAIL BY MISTAKE AND DELETE THIS E-MAIL FROM YOUR SYSTEM. E-MAIL TRANSMISSION CANNOT BE GUARANTEED TO BE SECURE OR ERROR-FREE AS INFORMATION COULD BE INTERCEPTED, CORRUPTED, LOST, DESTROYED, ARRIVE LATE OR INCOMPLETE, OR CONTAIN VIRUSES. THE SENDER THEREFORE DOES NOT ACCEPT LIABILITY FOR ANY ERRORS OR OMISSIONS IN THE CONTENTS OF THIS MESSAGE, WHICH ARISE AS A RESULT OF E-MAIL TRANSMISSION. IF VERIFICATION IS REQUIRED PLEASE REQUEST A HARD-COPY VERSION. COPYRIGHT 2018. ALL RIGHTS RESERVED BY WELLQUEST LIVING,LLC, AND ITS AFFILIATES. From: Raybould, Claire <Claire.Raybould@paloalto.gov> Sent: Monday, March 23, 2026 2:15 PM To: Charlene Kussner <charlene@wqliving.com> Item 10 Attachment B - Applicant Representative’s Withdrawal Letter        Item 10: Staff Report Pg. 8  Packet Pg. 138 of 489  Subject: RE: 4075 el camino way [EXTERNAL EMAIL] Yes of course. I’ll send an invite for 30 minutes though I don’t think we need that long. Feel free to forward to whomever else on your team you’d like to have attend. Claire From: Charlene Kussner <charlene@wqliving.com> Sent: Monday, March 23, 2026 1:13 PM To: Raybould, Claire <Claire.Raybould@paloalto.gov> Subject: RE: 4075 el camino way CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Can we do Wednesday? Charlene Kussner | V.P. of Development & Asset Management charlene@wqliving.com C: 951.757.2571 Corporate Office: 185 South State Street, Suite 1300, Salt Lake City, UT 84111 CA Office: Wellquest of Menifee Lakes, 29914 Antelope Road, Menifee CA 92586 “All that I have seen teaches me to trust the Creator for all I have not seen.” Ralph Waldo Emerson THIS MESSAGE CONTAINS CONFIDENTIAL INFORMATION AND IS INTENDED ONLY FOR THE INDIVIDUAL(S) NAMED. IF YOU ARE NOT THE NAMED ADDRESSEE(S) YOU SHOULD NOT DISSEMINATE, DISTRIBUTE OR COPY THIS E-MAIL. PLEASE NOTIFY THE SENDER IMMEDIATELY BY E-MAIL IF YOU HAVE RECEIVED THIS E-MAIL BY MISTAKE AND DELETE THIS E-MAIL FROM YOUR SYSTEM. E-MAIL TRANSMISSION CANNOT BE GUARANTEED TO BE SECURE OR ERROR-FREE AS INFORMATION COULD BE INTERCEPTED, CORRUPTED, LOST, DESTROYED, ARRIVE LATE OR INCOMPLETE, OR CONTAIN VIRUSES. THE SENDER THEREFORE DOES NOT ACCEPT LIABILITY FOR ANY ERRORS OR OMISSIONS IN THE CONTENTS OF THIS MESSAGE, WHICH ARISE AS A RESULT OF E-MAIL TRANSMISSION. IF VERIFICATION IS REQUIRED PLEASE REQUEST A HARD-COPY VERSION. COPYRIGHT 2018. ALL RIGHTS RESERVED BY WELLQUEST LIVING,LLC, AND ITS AFFILIATES. From: Raybould, Claire <Claire.Raybould@paloalto.gov> Sent: Monday, March 23, 2026 11:50 AM To: Charlene Kussner <charlene@wqliving.com> Item 10 Attachment B - Applicant Representative’s Withdrawal Letter        Item 10: Staff Report Pg. 9  Packet Pg. 139 of 489  Subject: 4075 el camino way [EXTERNAL EMAIL] Good morning Charlene, I had a chance to discuss council’s motion with our attorney further and I’d like to connect further with your team regarding options and next steps given the Council meeting last week. Do you have time for a quick call either at noon or 2pm today? Ot Wednesday at 1pm (I’m free until 1:30)? I think we only need about 10 minutes and then you can take that information to your team and get back to me about how you’d like to move forward. Claire Claire Raybould, AICP Manager, Current Planning Planning and Development Services Department (650) 329-2116 | Claire.Raybould@paloalto.gov www.cityofpaloalto.org Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms & Applications | Planning Applications Mapped Item 10 Attachment B - Applicant Representative’s Withdrawal Letter        Item 10: Staff Report Pg. 10  Packet Pg. 140 of 489  City Council Staff Report From: City Manager Report Type: ACTION ITEMS Lead Department: Planning and Development Services Meeting Date: April 20, 2026 Report #:2601-5873 TITLE Quasi-Judicial: Adoption of a Resolution Documenting the City Council’s Consideration and Decision on an Appeal of the Chief Building Official’s Order to Demolish the Buildings Located at 531 Stanford Avenue. RECOMMENDATION Staff recommend that the City Council Adopt a resolution denying the appeal and upholding the Chief Building Official's Order to Demolish the buildings on the subject property based on findings and conditions set forth in Attachment A. EXECUTIVE SUMMARY The property located at 531 Stanford Avenue consists of multiple structures that have been determined by the City Chief Building Official to be dangerous and unsafe, constituting public nuisances that pose substantial danger to health, safety, and general welfare. The buildings were originally permitted as R-1 occupancy (hotel) but were being operated as R-2 occupancy (residential apartments) without authorization. The enforcement history began on March 18, 2024, when City inspectors discovered numerous life-safety violations during an inspection. On March 21, 2024, the City issued a Notice of Violation identifying critical deficiencies including dilapidated fire sprinkler and alarm systems, lack of fire watch services, blocked egress routes, unpermitted construction, structural concerns, hazardous material storage issues, and numerous building code violations. Following the initial Notice of Violation, the property owner took some remedial actions to respond to the notice of violation. However, the underlying structural, fire safety, and code compliance issues remained unresolved. On April 2, 2024, Chief Building Official issued an Emergency Notice to Repair or Abate, and on April 9, 2024, the building was red tagged as unsafe for occupancy. After comprehensive assessment and determination that the structures could not be feasibly repaired to meet code requirements, the Chief Building Official issued a Notice and Order to Demolish on October 17, 2025. The Order was based on findings that the structures were fifty Item 11 Item 11 Staff Report        Item 11: Staff Report Pg. 1  Packet Pg. 141 of 489  percent or more damaged, decayed, or deteriorated, constituted fire hazards, and could not be repaired to eliminate code violations. BACKGROUND Item 11 Item 11 Staff Report        Item 11: Staff Report Pg. 2  Packet Pg. 142 of 489  • Non-functioning and missing egress exits and components. • Pool with visible mold underfloor/garage level, unhygienic Following issuance of the first Notice of Violation, the property owner took certain corrective actions to address immediate life-safety concerns. Fire watch services were implemented, tenants were evacuated from upper floors, and some hazardous conditions were remediated. However, the underlying structural deficiencies, extensive unpermitted construction, and code violations remained unresolved. A second Notice of Violation (Attachment C) was issued on March 28, 2024, to set new compliance deadlines for the outstanding violations. Subsequent Code Enforcement Action Based on the extensive violations, Chief Building Official George Hoyt, issued an Emergency Notice to Repair or Abate on April 2, 2024 (Attachment D). On April 3, 2024, the City issued a third Notice of Violation (Attachment E) for outstanding code violations and issued two administrative citations for failure to comply with previous Notices of Violation. On April 9, 2024, the buildings were red tagged as unsafe for occupancy (Attachment D) and the City issued a fourth and final Notice of Violation (Attachment F). PAMC Section 16.40.050(c) permits mandatory demolition when any one of three independent conditions exists. Meeting a single criterion is sufficient to require demolition. The three criteria are: (1) a dangerous building is fifty percent or more damaged, decayed, or deteriorated from replacement value or structure; (2) a building cannot be repaired so that it will no longer exist in violation of Chapter 16.40; or (3) a dangerous building is a fire hazard existing or erected in violation of applicable codes. The Chief Building Official determined that the buildings met the mandatory demolition criteria established in PAMC Section 16.40.050, specifically finding that the buildings: were fifty percent or more damaged, decayed, or deteriorated from replacement value or structure; could not be repaired to eliminate violations of PAMC Chapter 16.40; and constituted fire hazards existing in violation of applicable codes. While satisfaction of any single criterion would have been sufficient to require demolition, the finding that all three criteria are met provides additional support for the demolition order. On October 16, 2025, the Chief Building Official issued a formal Notice and Order to Demolish the buildings in accordance with California Health and Safety Code Section 17980.6 and PAMC Chapter 16.40 (Attachment G). On November 7, 2025, Stanford Orion, the property manager and owner representative sent a letter to the City outlining some concerns with the Notice and Order to Demolish (Attachment H). On November 13, 2025, Stanford Orion filed a written appeal of the Notice and Order to Item 11 Item 11 Staff Report        Item 11: Staff Report Pg. 3  Packet Pg. 143 of 489  Demolish (Attachment I). The appeal was submitted through Stanford Orion’s attorneys, Patterson & O'Neill, PC, and raises four principal arguments: (1) improper service; (2) failure to meet demolition threshold; (3) unlawful deconstruction requirement; and (4) unreasonable timeline. ANALYSIS Item 11 Item 11 Staff Report        Item 11: Staff Report Pg. 4  Packet Pg. 144 of 489  Objection 1: Alleged Improper Notice The appellant contends that the Notice and Order was not properly served because the City mailed it to the vacant building at 531 Stanford Avenue. The Notice and Order was properly served in full compliance with PAMC Section 16.40.060. The City mailed the notice to the property address appearing on county tax records, which is expressly authorized by PAMC Section 16.40.060(d). The code specifies that failure to receive notice does not affect validity and service by certified mail is effective on the date of mailing. Moreover, the appellant timely filed an appeal, demonstrating actual notice. In addition to the certified mail service required by code, the City also provided courtesy email notification of the Notice and Order to the property owner and their previous legal counsel. When Patterson & O'Neill subsequently informed the City that they had not received the email, staff offered a courtesy extension of time to respond to the Notice and Order. This accommodation provided the appellant with additional time beyond the code-required deadlines to review the order and prepare their response. The Declaration of Code Enforcement Manager Elisa Vargas (Attachment K) supports the City’s position that the notice was issued in accordance with municipal regulations. The appellant contends that violations do not establish that the building is fifty percent damaged, decayed or deteriorated from replacement value. The appellant misunderstands the standards. PAMC Section 16.40.050(c) establishes three independent grounds for mandatory demolition, but only one standard must be satisfied to require demolition. The buildings meet all three criteria: (1) fifty percent or more damage based on comprehensive assessment of structural deficiencies, failed systems, and code violations; (2) cannot be repaired so that it will no longer exist in violation of Chapter 16.40; or (3) constitute fire hazards. The declaration of the Chief Building Official (Attachment J) supports mandatory demolition of the buildings at 531 Stanford Avenue under the first criterion. Based on a March 2024 inspection, ongoing monitoring, and professional expertise, the Chief Building Official determined that rehabilitation costs exceed fifty percent of replacement value. This conclusion rests on the cumulative impact of failed and non-functional fire protection systems, systemically corroded electrical and plumbing infrastructure, structural failure requiring emergency shoring, extensive unpermitted construction whose hidden conditions cannot be assessed without demolition, and eighteen months of post-vacancy deterioration that worsened all pre-existing deficiencies. Taken together, the cost of full system replacement, structural reconstruction, unpermitted work remediation, and hazardous materials abatement exceeds the fifty percent threshold, satisfying the first demolition criterion. Item 11 Item 11 Staff Report        Item 11: Staff Report Pg. 5  Packet Pg. 145 of 489  The determination that the buildings cannot be repaired so that it will no longer exist in violation of PAMC Chapter 16.40 is supported by the scope and interconnected nature of the violations. Installing new fire protection systems would require demolition throughout the buildings to access concealed spaces for piping and wiring. Reconstructing the structurally failing exit balcony affects the building's egress system and fire-rated assemblies. Replacing corroded electrical and plumbing systems necessitates opening walls, ceilings, and floors throughout multiple buildings. Remediating the extensive unpermitted construction requires demolition to verify structural adequacy and code compliance. Providing code-compliant egress for the unauthorized R-2 occupancy requires reconfiguring building layouts. The scope of work necessary to eliminate all code violations constitutes reconstruction of the buildings rather than repair. The Declarations of Chief Building Official George Hoyt (Attachment J) and Fire Marshal Tami Jasso (Attachment L) explain why repair is not feasible, supported by photographic evidence (Attachment M). Objection 3: Request for Deconstruction Instead of Demolition Item 11 Item 11 Staff Report        Item 11: Staff Report Pg. 6  Packet Pg. 146 of 489  Objection 4: Claims Regarding Timing and Other Issues The appellant contends that the May 18, 2026 compliance deadline is unreasonable for three stated reasons: (1) the deadline requires removal during the wet season which can cause delays, increase costs, and create dangerous conditions; (2) essential public health and safety equipment is located on the building with no plan to address this equipment; and (3) the City has delayed approval of a post-demolition plan and the vacant property will continue to be a magnet for nuisance activities. As an initial matter, the filing of the appeal on November 13, 2025, has stayed enforcement of the Notice and Order pursuant to PAMC § 16.40.080(f). The compliance deadlines are not currently in effect and will remain stayed until the City Council issues its decision. If the City Council upholds the demolition order, new compliance deadlines will be established based on the date of the Council's decision. As noted in attached resolution (Attachment A), staff's recommendation includes a six-month timeframe from the Council's decision for complete removal of all structures. Six months is a reasonable timeframe based on standard industry practice for low-rise demolition projects, and includes permitting and regulatory approvals, hazardous material abatement, conventional excavator-based structural demolition, below-grade structure removal, debris hauling, and final site restoration. The appellant's concern about demolition during wet season does not justify delaying the demolition requirement. The six-month timeframe provides flexibility for the property owner to schedule demolition work during favorable weather conditions within the compliance period. The appellant references "essential public health and safety equipment" located on the building, referring to wireless telecommunications equipment on the roof. This claim does not provide grounds to reverse or delay the demolition order. The appellant has not provided documentation establishing that the rooftop equipment is "essential" to public health and safety, provides unique coverage not available from other facilities, or that its removal would create a public safety gap. City staff requested such documentation prior to the appeal being filed, but it was not provided. City staff consulted with emergency response personnel regarding wireless coverage in the area. The feedback did not identify any concerns that could not be mitigated through existing infrastructure or services. Removal of commercial wireless equipment from this building is not anticipated to compromise emergency communications. Wireless carriers routinely relocate equipment when buildings are demolished. Standard telecommunications site leases contain provisions addressing lease termination and equipment Item 11 Item 11 Staff Report        Item 11: Staff Report Pg. 7  Packet Pg. 147 of 489  removal. The appellant was asked to provide lease documentation but did not do so. The responsibility to maintain wireless coverage rests with the carriers, not with the property owner or City. Wireless carriers can seek alternative locations for equipment including other rooftop sites, tower facilities, and small cell installations. If equipment needs relocation, carriers can pursue permit applications for alternative sites through normal processes. Housing Applications and Processing Concerns Item 11 Item 11 Staff Report        Item 11: Staff Report Pg. 8  Packet Pg. 148 of 489  six-month timeline and conditions are reasonable and necessary; (6) the buildings qualify for exemption from mandatory deconstruction requirements under PAMC § 5.24.080(a)(3); (7) the appeal arguments do not provide sufficient grounds to reverse the Notice and Order to Demolish; and (8) complete demolition serves the public interest in protecting health, safety, and general welfare. The resolution also establishes five conditions of approval governing demolition timeline, site remediation, permit requirements, perimeter fencing, and ongoing site maintenance. If the City Council upholds the demolition order, staff recommend adoption of the attached resolution upholding the demolition order. FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT ENVIRONMENTAL REVIEW ATTACHMENTS Item 11 Item 11 Staff Report        Item 11: Staff Report Pg. 9  Packet Pg. 149 of 489  J. Declaration of George Hoyt, Chief Building Official APPROVED BY: Item 11 Item 11 Staff Report        Item 11: Staff Report Pg. 10  Packet Pg. 150 of 489  RESOLUTION NO. ______ RESOLUTION OF THE COUNCIL OF THE CITY OF PALO ALTO FOR 531 STANFORD AVENUE: APPEAL OF CHIEF BUILDING OFFICIAL ORDER TO DEMOLISH (24PCE- 00203) On April 20, 2026, the City Council of the City of Palo Alto denied the appeal and upheld the Chief Building Official Order to Demolish the structures located at 531 Stanford Avenue, making the following findings, determinations and declarations: SECTION 1. Background. The City Council of the City of Palo Alto ("City Council") finds, determines, and declares as follows: A. The subject property is located at 531 Stanford Avenue, Palo Alto, CA 94306; Assessor Parcel Numbers: 137-01-121, 137-01-002, 137-01-003; Property Owner: Aurora Rising Inc/Atlas Star LLC; Case Number: 24PCE-00203. B. Following a comprehensive inspection conducted on March 18, 2024, the City issued a Notice of Violation on March 21, 2024, identifying numerous serious violations affecting life safety, structural integrity, fire protection systems, and building code compliance. The Notice identified critical deficiencies requiring immediate remedial action including dilapidated fire sprinkler and alarm systems; lack of fire watch services; high combustible storage; improper hazardous material storage; severely corroded electrical and plumbing systems; unpermitted remodeling and construction; potential structural failure of second floor exit balcony requiring shoring; expired Use and Occupancy permit with unauthorized R-2 use; inoperable elevators; blocked egress; non-functioning fire-rated exits; exposed mold growth; and vermin infestation. C. Based on the extensive violations and determination that the buildings could not be feasibly repaired to meet code requirements, Chief Building Official George Hoyt issued an Emergency Notice to Repair or Abate on April 2, 2024, pursuant to authority under PAMC Chapter 16.40. D. On April 9, 2024 the buildings were red-tagged as unsafe for occupancy pursuant to the Chief Building Official authority under PAMC Chapter 16.40. The buildings have remained red-tagged continuously since that date. Item 11 Attachment A - Draft Resolution Upholding Chief Building Official Notice to Demolish v2        Item 11: Staff Report Pg. 11  Packet Pg. 151 of 489  E. On October 17, 2025, following comprehensive evaluation, Chief Building Official George Hoyt issued a formal Notice and Order to Demolish in accordance with California Health and Safety Code § 17980.6 and PAMC Chapter 16.40. The Notice documented that the property contains dangerous and unsafe conditions constituting public nuisances posing substantial danger to health, safety, and general welfare. The Notice identified 18 specific categories of code violations and ordered demolition permit application by November 17, 2025 and completion by May 18, 2026. The Notice was delivered via posting, first-class mail, and certified mail (tracking number 9589 0710 5270 2033 2917 42) to Aurora Rising Inc/Atlas Star at 531 Stanford Avenue, the address on Santa Clara County property tax records. F. On November 7, 2025, the property owner representative submitted a letter to the City expressing concerns regarding the Notice and Order, including timeline extension requests. City staff met with the representative to discuss issues raised. G. On November 13, 2025, Stanford Orion, the property manager and owner representative, filed a timely written appeal pursuant to PAMC § 16.40.080. The appeal, submitted through Patterson & O'Neill, PC, raised four objections: (1) improper service; (2) failure to meet demolition threshold; (3) unlawful deconstruction requirement; and (4) unreasonable timeline. Pursuant to PAMC § 16.40.080(f), the appeal stayed enforcement. H. The administrative record includes expert declarations from City officials: Declaration of George E. Hoyt, Chief Building Official; Declaration of Elisa Vargas, Code Enforcement Supervisor; and Declaration of Tamara Jasso, Fire Marshal. These declarations are supported by photographic evidence and documentary exhibits. I. On April 20, 2026, the City Council held a duly noticed public hearing. Notice was provided to the appellant and property owner by certified mail at least seven days prior in accordance with PAMC § 16.40.080(b). The Council considered the administrative record, staff reports, expert declarations, documentary and photographic evidence, and testimony. SECTION 2. Environmental Review. This action is exempt from the California Environmental Quality Act (CEQA) under two independent exemptions: (1) Emergency Projects Exemption (CEQA Guidelines § 15269(c)) as demolition is necessary to address imminent public health and safety threats posed by dangerous structures; and (2) Common Sense Exemption (CEQA Guidelines § 15061(b)(3)) as there is no possibility that demolition of existing dangerous structures will have a significant environmental effect. Item 11 Attachment A - Draft Resolution Upholding Chief Building Official Notice to Demolish v2        Item 11: Staff Report Pg. 12  Packet Pg. 152 of 489  SECTION 3. Findings 1. The buildings at 531 Stanford Avenue constitute dangerous buildings as defined in PAMC § 16.40.010 and substandard residential buildings as defined in PAMC § 16.40.020 . 2. Palo Alto Municipal Code section 16.40.050(c) requires mandatory demolition when any one of three independent conditions exists. Meeting any single criterion is sufficient. The buildings meet all three criteria: (a) Fifty percent or more damaged, decayed, or deteriorated based on comprehensive assessment of failed fire protection systems, severely corroded electrical and plumbing systems, structural deterioration requiring emergency shoring, extensive unpermitted construction, and deteriorated building systems; (b) Cannot be repaired so that they will no longer exist in violation of PAMC Chapter 16.40 because the scope of necessary work constitutes reconstruction rather than repair; (c) Fire hazards existing or erected in violation of the terms of this chapter, ordinances of this City, and statutes of the State of California. 3. The Notice and Order was properly served by certified mail to the address on Santa Clara County property tax records as authorized by PAMC § 16.40.060(d). Service is effective on mailing regardless of receipt. The timely appeal demonstrates actual notice. The Chief Building Official acted within authority under PAMC § 16.40.060(a). 4. The determination upholding the order to demolish the subject buildings is supported by substantial evidence including: March 18, 2024 comprehensive inspection; October 16, 2025 Notice and Order documenting 18 specific code violations; ongoing red-tag status since April 2024; City records showing lack of required permits; expert declarations from the Chief Building Official, Code Enforcement Supervisor, and Fire Marshal; and supporting photographic and documentary exhibits. 5. The six-month timeframe to demolish the building and associated improvements and to prepare the site in accordance with the applicable conditions is reasonable and sufficient to allow for the procurement of required permits, completion of hazardous material abatement, performance of structural demolition and debris hauling, and final site restoration, while addressing urgent safety concerns. Complete removal of all structures, including subterranean improvements, is necessary to fully abate hazardous conditions. Site grading and installation of perimeter fencing are required to protect public health and safety. Item 11 Attachment A - Draft Resolution Upholding Chief Building Official Notice to Demolish v2        Item 11: Staff Report Pg. 13  Packet Pg. 153 of 489  6. The buildings qualify for exemption from mandatory deconstruction under PAMC § 5.24.080(a) as dangerous buildings required to be abated by demolition. The property owner may use standard demolition methods or voluntarily elect deconstruction. 7. The appeal arguments do not provide sufficient grounds to reverse the order. The service of proper notice argument is contradicted by code provisions and the timely appeal. The dangerous conditions challenge misunderstands the three independent criteria. The deconstruction argument does not undermine the demolition requirement. The timeline concerns do not justify postponement given the nearly two-year enforcement history. 8. Complete demolition is necessary to protect health, safety, and general welfare. The buildings present ongoing threats including partial structural collapse risk, unabated fire hazards, unauthorized occupancy risk, and environmental hazards. The City has a fundamental obligation under PAMC Chapter 16.40 and California Health and Safety Code § 17980.6 to protect public safety. A vacant, graded, and secured lot presents substantially lower risks than deteriorating dangerous structures. SECTION 4. Appeal Denied and Demolition Order Upheld. Based on the foregoing findings and substantial evidence, the City Council denies the appeal and upholds the Chief Building Official Order to Demolish the structures at 531 Stanford Avenue, effective March 2, 2026 and subject to the conditions set forth in Section 5. SECTION 5. Conditions of Approval. 1. All structures, including above-ground buildings and below-ground improvements such as the subterranean garage and swimming pool, shall be completely removed and the site secured no later than October 20, 2026, or within six (6) months of the City Council final decision, whichever is later. The property owner must obtain all required approvals and final inspections from the City Planning and Development Services Department prior to this deadline. Item 11 Attachment A - Draft Resolution Upholding Chief Building Official Notice to Demolish v2        Item 11: Staff Report Pg. 14  Packet Pg. 154 of 489  2. All subterranean excavations resulting from removal of below-ground structures shall be filled with approved materials and graded level with the surrounding site to ensure proper drainage and site stability. 3. A complete application for demolition permit shall be filed with the City Planning and Development Services Department within thirty (30) days of the City Council final action. Pursuant to PAMC § 5.24.080(a)(3), no deconstruction shall be required; the property owner may use standard demolition methods. 4. A six-foot tall wood or chain-link fence with integrated screening shall be installed and maintained around the perimeter of the property to secure it from unauthorized access. Upon written notice from the City, any deterioration, damage, tears, fraying, graffiti, or similar conditions shall be replaced or corrected within ten (10) days of written notice. 5. The property owner shall maintain the site in a clean, safe, and secure condition at all times. The site shall be kept free of trash, debris, overgrown vegetation, standing water, and similar property maintenance issues. Regular maintenance including mowing, weeding, and litter removal shall be performed as necessary. The property owner shall respond to any written notice from the City regarding site maintenance issues within ten (10) days of notice. SECTION 6. Effective Date and Finality. This decision is final upon adoption by the City Council on April 20, 2026. Pursuant to PAMC § 16.40.080(e), the City Council has affirmed the Chief Building Official order with the conditions specified herein. This decision is final and not subject to further administrative appeal. PASSED: AYES: NOES: ABSENT: ABSTENTIONS: Item 11 Attachment A - Draft Resolution Upholding Chief Building Official Notice to Demolish v2        Item 11: Staff Report Pg. 15  Packet Pg. 155 of 489  CERTIFICATION I hereby certify that the foregoing is a true and correct copy of the Resolution adopted by the City Council of the City of Palo Alto at its meeting held on April 20, 2026. Dated: ________________________ _______________________________________ Mahealani Ah Yun, City Clerk City of Palo Alto Item 11 Attachment A - Draft Resolution Upholding Chief Building Official Notice to Demolish v2        Item 11: Staff Report Pg. 16  Packet Pg. 156 of 489  Item 11 Attachment B - First Notice of Violation (March 21, 2024)        Item 11: Staff Report Pg. 17  Packet Pg. 157 of 489  Item 11 Attachment B - First Notice of Violation (March 21, 2024)        Item 11: Staff Report Pg. 18  Packet Pg. 158 of 489  Item 11 Attachment B - First Notice of Violation (March 21, 2024)        Item 11: Staff Report Pg. 19  Packet Pg. 159 of 489  Item 11 Attachment B - First Notice of Violation (March 21, 2024)        Item 11: Staff Report Pg. 20  Packet Pg. 160 of 489  Item 11 Attachment B - First Notice of Violation (March 21, 2024)        Item 11: Staff Report Pg. 21  Packet Pg. 161 of 489  Item 11 Attachment B - First Notice of Violation (March 21, 2024)        Item 11: Staff Report Pg. 22  Packet Pg. 162 of 489  Item 11 Attachment C - Second Notice of Violation (March 28, 2024)        Item 11: Staff Report Pg. 23  Packet Pg. 163 of 489  Item 11 Attachment C - Second Notice of Violation (March 28, 2024)        Item 11: Staff Report Pg. 24  Packet Pg. 164 of 489  Item 11 Attachment C - Second Notice of Violation (March 28, 2024)        Item 11: Staff Report Pg. 25  Packet Pg. 165 of 489  Item 11 Attachment D - Emergency Notice to Repair or Abate (April 2, 2024)        Item 11: Staff Report Pg. 26  Packet Pg. 166 of 489  You are required to provide minimal living standards to all occupants of the dwelling unit(s). City records show that the buildings located at 531 Stanford Avenue (also known as 520 Oxford Avenue) currently lack proper permits and authorizations for legal use and occupancy. There are no permits on file for 520 Oxford Avenue for an address assignment request. There are also no permits on file that approve or certify residential usage, building alterations or remodeling, fire alarm or sprinkler systems, hazardous materials handling, or pool operation. Due to this substantial lack of required permits and inspections, the ,buildings are presently classified as unsafe structures with multiple substandard conditions. Some of the identified deficiencies include, but are not limited to the following: •Dilapidated & Missing emergency Exit Signage and Emergency lighting. (PAMC § 16.40.010 (a)) •Dilapidated Fire Sprinkler & Fire Alarm Systems. (PAMC § 15.04.010, 16.40.010 (p); CFC§ 311.2.2) •Unconfirmed records of testing for Fire Sprinklers & Fire Alarm Systems. {PAMC § 16.40.010 (p); CFC §107.3) •High combustible storage throughout all buildings. (PAMC § 16.40.010 (p)) •Improper Hazmat storage which has created corrosive environments and conditions. (PAMC § 16.40.010 (p)) •Severely corroded electrical and plumbing systems. (PAMC § 16.40.010 {p)) •Plastic film (unapproved building material) on ceilings in some units and in exit stairways. (PAMC § 16.40.010 (p); CFC§ 311.3) •Unpermitted construction (shoring): Structural, potential failure of 2nd Floor exit balcony that appears to be shored for stability. (PAMC § 15.04.010; CBC§ 105.1) •Unpermitted remodeling of all hotel rooms and throughout buildings (Includes: Enclosing decks, patios, & roof coverings). (PAMC § 15.04.010; CRC § R113.1} •Unpermitted construction; Electrical (exposed and unsafe wiring throughout all buildings), Mechanical (Water Heaters, boilers and holding tanks), Plumbing (New fixtures and repairs throughout buildings) and Mechanical ventilation and exhaust. (PAMC § 16.40.010 (p)) •Unpermitted construction; Non-Structural. {Gazebo structures). (PAMC § 15.04.010; CBC§ 105.1) •Unauthorized Use and Occupancy (originally permitted for R-1, now being used as R-2). (PAMC § 16.40.020 {I)) •Inoperable Elevators (expired certifications) CCR Title 8§3001. Permit to Operate. (c) •Blocked Egress -Stanford Avenue side and throughout buildings. (PAMC §§ 16.40.010 (a), 16.40.020 (j)) •Non-functioning and missing Egress Exits (fire-rated doors and door frames). (PAMC § 16.40.010 (a), 16.40.020 (j)) •Exposed mold growth in basement. (PAMC §§ 16.40.010 (n), 16.40.020 (i), 16.40.020 (m)) Page 2 of 7 Item 11 Attachment D - Emergency Notice to Repair or Abate (April 2, 2024)        Item 11: Staff Report Pg. 27  Packet Pg. 167 of 489  Item 11 Attachment D - Emergency Notice to Repair or Abate (April 2, 2024)        Item 11: Staff Report Pg. 28  Packet Pg. 168 of 489  Item 11 Attachment D - Emergency Notice to Repair or Abate (April 2, 2024)        Item 11: Staff Report Pg. 29  Packet Pg. 169 of 489  Item 11 Attachment D - Emergency Notice to Repair or Abate (April 2, 2024)        Item 11: Staff Report Pg. 30  Packet Pg. 170 of 489  Item 11 Attachment D - Emergency Notice to Repair or Abate (April 2, 2024)        Item 11: Staff Report Pg. 31  Packet Pg. 171 of 489  Item 11 Attachment D - Emergency Notice to Repair or Abate (April 2, 2024)        Item 11: Staff Report Pg. 32  Packet Pg. 172 of 489  Item 11 Attachment D - Emergency Notice to Repair or Abate (April 2, 2024)        Item 11: Staff Report Pg. 33  Packet Pg. 173 of 489  Item 11 Attachment D - Emergency Notice to Repair or Abate (April 2, 2024)        Item 11: Staff Report Pg. 34  Packet Pg. 174 of 489  Item 11 Attachment D - Emergency Notice to Repair or Abate (April 2, 2024)        Item 11: Staff Report Pg. 35  Packet Pg. 175 of 489  Item 11 Attachment E - Third Notice of Violation (April 3, 2024)        Item 11: Staff Report Pg. 36  Packet Pg. 176 of 489  Item 11 Attachment E - Third Notice of Violation (April 3, 2024)        Item 11: Staff Report Pg. 37  Packet Pg. 177 of 489  Item 11 Attachment E - Third Notice of Violation (April 3, 2024)        Item 11: Staff Report Pg. 38  Packet Pg. 178 of 489  Item 11 Attachment E - Third Notice of Violation (April 3, 2024)        Item 11: Staff Report Pg. 39  Packet Pg. 179 of 489  Item 11 Attachment E - Third Notice of Violation (April 3, 2024)        Item 11: Staff Report Pg. 40  Packet Pg. 180 of 489  Item 11 Attachment E - Third Notice of Violation (April 3, 2024)        Item 11: Staff Report Pg. 41  Packet Pg. 181 of 489  Item 11 Attachment F - Fourth Notice of Violation (April 9, 2024)        Item 11: Staff Report Pg. 42  Packet Pg. 182 of 489  Item 11 Attachment F - Fourth Notice of Violation (April 9, 2024)        Item 11: Staff Report Pg. 43  Packet Pg. 183 of 489  Item 11 Attachment F - Fourth Notice of Violation (April 9, 2024)        Item 11: Staff Report Pg. 44  Packet Pg. 184 of 489  Item 11 Attachment F - Fourth Notice of Violation (April 9, 2024)        Item 11: Staff Report Pg. 45  Packet Pg. 185 of 489  Item 11 Attachment F - Fourth Notice of Violation (April 9, 2024)        Item 11: Staff Report Pg. 46  Packet Pg. 186 of 489  Item 11 Attachment F - Fourth Notice of Violation (April 9, 2024)        Item 11: Staff Report Pg. 47  Packet Pg. 187 of 489  Item 11 Attachment F - Fourth Notice of Violation (April 9, 2024)        Item 11: Staff Report Pg. 48  Packet Pg. 188 of 489  Item 11 Attachment F - Fourth Notice of Violation (April 9, 2024)        Item 11: Staff Report Pg. 49  Packet Pg. 189 of 489  Item 11 Attachment F - Fourth Notice of Violation (April 9, 2024)        Item 11: Staff Report Pg. 50  Packet Pg. 190 of 489  Item 11 Attachment F - Fourth Notice of Violation (April 9, 2024)        Item 11: Staff Report Pg. 51  Packet Pg. 191 of 489  Item 11 Attachment G - Notice and Order to Demolish (October 16, 2025)        Item 11: Staff Report Pg. 52  Packet Pg. 192 of 489  Item 11 Attachment G - Notice and Order to Demolish (October 16, 2025)        Item 11: Staff Report Pg. 53  Packet Pg. 193 of 489  Item 11 Attachment G - Notice and Order to Demolish (October 16, 2025)        Item 11: Staff Report Pg. 54  Packet Pg. 194 of 489  Item 11 Attachment G - Notice and Order to Demolish (October 16, 2025)        Item 11: Staff Report Pg. 55  Packet Pg. 195 of 489  Item 11 Attachment G - Notice and Order to Demolish (October 16, 2025)        Item 11: Staff Report Pg. 56  Packet Pg. 196 of 489  Item 11 Attachment G - Notice and Order to Demolish (October 16, 2025)        Item 11: Staff Report Pg. 57  Packet Pg. 197 of 489  Item 11 Attachment G - Notice and Order to Demolish (October 16, 2025)        Item 11: Staff Report Pg. 58  Packet Pg. 198 of 489  PATTERSON & O’NEILL, PC 235 Montgomery Street, Suite 950 San Francisco, CA 94104 Telephone: (415) 907-9110 Facsimile: (415) 907-7704 www.pattersononeill.com VIA EMAIL City of Palo Alto George Hoyt, Chief Building Official Planning and Development Services Department 250 Hamilton Ave. Palo Alto, CA 94301 Re: Notice and Order to Demolish/Deconstruct and Remove Buildings 531 Stanford Avenue Dear Mr. Hoyt: The City has issued a Notice and Order to Demolish/Deconstruct and Remove Buildings (“Notice”) to my client regarding the existing buildings at 531 Stanford Avenue. The Notice contains multiple factual and legal inaccuracies, and the purpose of this letter to correct the record and address next steps. The Notice seems to suggest that the owners have been dilatory in addressing the City’s concerns regarding the building. Nothing could be farther from the truth. In many respects, the delays in addressing the building have been caused by the City and its ever- shifting demands. While my client disagrees that the building meets the requirements under PAMC § 16.40.050(c) that would require the building to be demolished, my client nonetheless does not intend to appeal the Notice at this time because my client shares the City’s desire to remove the building. First, we must note that the City apparently mailed the Notice to the building at 531 Stanford Avenue, which the City knows is vacant, fenced, and inaccessible. The City did not properly serve the Notice pursuant to the requirements of PAMC § 16.40.060. We appreciate that Elisa Vargas, Building Inspector, confirmed in writing that the 15-day period to appeal the Notice would run from October 29, 2025. Again, my client hopes to avoid an appeal, but reserves the right to do so. Property History My clients first become involved in the property 531 Stanford Avenue in 2010, when the property was purchased by Fortune Sun, Inc. (“Fortune”). This entity took over the existing Stanford Terrace Inn (“STI”), a well-known hotel that had operated for decades prior to Fortune’s ownership. The STI had a long history of hosting many guests for long-term stays, Item 11 Attachment H - Letter from Property Owner Representative (November 7, 2025)        Item 11: Staff Report Pg. 59  Packet Pg. 199 of 489  including faculty members who used STI as their residence, as well as short-term transient guests. In 2018, the building was sold to Aurora Rising, Inc. (“Aurora”), who continued to operate the STI in the same manner. In the Spring of 2020, as a result of COVID, STI rapidly lost its transient customer base, began to operate at a loss, and was forced to lay off most of its staff. The few customers who remained were non-transient residents, specifically Stanford faculty members and students who continued to reside at the property. On or about June 18, 2021, the City of Palo Alto sent a letter to the ownership of STI, expressing preliminary interest in purchasing the subject property for possible inclusion in the State’s Project HomeKey program to provide housing for unhoused residents. The City sent similar inquiries in 2022 and sent information regarding affordable housing opportunities again to company’s closed registered business email address. In May of 2023, ownership contacted the City Manager regarding potential redevelopment of the property for housing, including by submitting two different housing proposals. Ownership also requested that the City include the property in its Housing Element rezoning program. The City failed to include the property in its rezoning program and also failed to provide ownership with the necessary application forms to complete the redevelopment plans. On February 28, 2024, the City sent a “courtesy notice” of the City’s intention to inspect the STI because an enforcement “investigation” had determined the STI property appeared to be used for long term stays that were not permitted under current regulations – even though the STI had long been used for such purposes and the City had certainly been aware of this well-established use for years. The City’s position was that the hotel use had been abandoned, the property was zoned RM-30, and the City made clear that its preference was for the property to be developed for high density housing. Ownership believes that this particular property had been singled out by the City for disparate treatment, as many other hotels in the City also regularly allow long term stays, yet no investigations have been opened against other properties. Three days after the Planning Department met with the property management’s legal representative on March 18 to discuss redevelopment options, the City issued a formal Notice of Violation citing numerous violations such as lack of fire sprinklers and alarms, high combustible storage, unpermitted electrical and structural work, corroded plumbing, blocked egress routes, and inoperable elevators. The Notice required immediate fire-watch services by March 22, evacuation of upper floors and numerous corrective actions by March 25, 2024, and warned of possible declarations of substandard conditions, fines, or abatement orders if compliance was not achieved. After years of cooperative engagement with the City regarding potential redevelopment of the STI property, we believe the owners’ decision not to sell the property to the City or repurpose it in accordance with the City’s preferred high-density housing agenda provoked a campaign of retaliation that ultimately led to the Notice of Violation and the building being deemed uninhabitable. These actions have caused my client significant harm, both monetarily and emotionally. The City has now decided that the building – which just less than three years ago Item 11 Attachment H - Letter from Property Owner Representative (November 7, 2025)        Item 11: Staff Report Pg. 60  Packet Pg. 200 of 489  the City wanted to purchase – is so dilapidated and dangerous that it must be demolished in a matter of months. Findings and Violations The Notice repeats many of the same findings that were issued in the prior Notice of Violation. A number of the cited “violations” are inaccurate, immaterial, or grossly overstated, creating the false impression that ownership was a negligent operator rather than a reputable and conscientious business that had long operated a three-star hotel and, during extraordinarily difficult pandemic and post-pandemic years, allowed Stanford faculty and students to reside in quality accommodations at a fraction of market value. Many of these findings and violations have been addressed or are only relevant to issues of habitability. As the City is well aware, the building is not currently occupied or used for habitation purposes. Thus, it is unclear why these largely erroneous findings have been repeated in the current Notice, except to continue to harass my client and create a false impression that ownership has done nothing to address the building. For much of the last two years, the City’s position has been that the building cannot be demolished without an approved redevelopment plan. In fact, ownership submitted a demolition permit over a year ago and the City refused to accept it. Ownership has taken several remedial steps to address the purported violations, including, but not limited to, addressing the alleged hazardous materials remediation that the City mandated to “close” the property. Less than two months ago, the City informed ownership that the City had changed its mind and now wants the building demolished regardless of redevelopment plan. The Notice erroneously suggests that ownership has simply ignored the Notice of Violation over the last year, which is simply false. Ownership has diligently addressed all the actions that the City has requested, including as recently as last month when the City demanded vegetation removal. The only reason the building has not yet been demolished is because the City has until two months ago refused to consider demolition until a redevelopment plan is approved, yet continually stonewalled ownership’s efforts at redevelopment. Required Remedial Action 1. Deconstruction and Hazmat Closure Permits The Notice demands that the applicant take immediate steps to submit two applications by November 17, 2025 – giving the applicant approximately three weeks to comply after the City sat on the submitted demolition permit for a year. Both of the City’s demands are flawed. The City demands that the applicant submit a complete deconstruction permit. First, we again note the applicant submitted a demolition application in October 2024. The City had this application for over a year and never identified any deficiencies. This same exact application was submitted again last month. Item 11 Attachment H - Letter from Property Owner Representative (November 7, 2025)        Item 11: Staff Report Pg. 61  Packet Pg. 201 of 489  Second, the Notice cites to PAMC § 5.24 in support of the City’s demand for deconstruction. The City’s demand for deconstruction is not authorized by code. Please be advised that PAMC § 5.24.080 clearly states the following: 5.24.080 Exclusions. The provisions of this chapter shall not apply to the following: (a) Dangerous Structures. Any building or structure that has been determined to be dangerous, structurally unsafe or otherwise hazardous to human life, and is required to be abated by demolition. The City has determined that 531 Stanford is a dangerous building that is required to be abated by demolition. The City’s requirement for deconstruction in PAMC § 5.24 clearly does not apply, and we are unaware of any other code basis that would authorize the City to require deconstruction. While ownership will voluntarily recycle and reuse materials as much as possible, deconstruction cannot be legally required. WE DEMAND THAT YOU CONFIRM DECONSTRUCTION IS NOT REQUIRED BY NOVEMBER 12. If the City fails to confirm by this date, ownership may have no choice but to appeal the Notice on the basis that the City cannot legally require deconstruction of a dangerous building abated by demolition per PAMC § 5.24.080. Second, we find the City’s demand for a Hazmat Closure Permit puzzling. The applicant has already submitted a Hazmat Closure Permit, which was approved by the City. Much of the remedial action has already been completed. On August 19, 2025, the applicant submitted a permit extension/reactivation request form to Mike Espeland of the Palo Alto Fire Department. In short, ownership has already submitted this permit, and it is unclear what further actions the City needs ownership to complete. 1. Building Removal As noted above, ownership shares the City’s desire to remove the building. However, we believe that the date of May 18, 2026 is unreasonable for several reasons. First, much of the compliance deadline period (November-May) occurs during the winter months when rain is much more likely. Rain can cause significant delays and can create hazardous conditions during demolition. Ownership would request that the City at least push back the compliance deadline to allow demolition to take place during the dry season. Second, as the City is aware, currently there is a T-Mobile tower that provides essential 911 communications on the existing building. During our meeting on September 11, 2025 – where the City for the first time stated demolition without redevelopment would be required – City representatives confirmed that they would afford the property owners sufficient time to work with T-Mobile to discuss potential relocation of this equipment. Approximately one month later, Item 11 Attachment H - Letter from Property Owner Representative (November 7, 2025)        Item 11: Staff Report Pg. 62  Packet Pg. 202 of 489  the Notice now demands removal with no plan in place and with no regard for this critical safety infrastructure. The City must approve a relocation plan for this equipment prior to demolition. Third, the owners have already suffered significant financial losses following the pandemic, the liabilities and fines stemming from the City’s enforcement actions, and costs associated with remedial actions. Demolition activities also come with significant costs, and ownership is concerned that a vacant property with no active use will continue to be a magnet for nuisance activities. Ownership submitted an SB 330 application subject to AB 130 on August 19, and the City has failed to carry out its ministerial duties to conduct tribal scoping and process the application. Ownership must be able to put the property to an economically beneficial use following demolition, both to help fund the demolition activities and deter nuisance activities. Ownership would like to request a meeting with City staff to discuss the timing of demolition, as well as alternatives for the T-mobile tower and post-demolition uses. Potential alternatives include: 1) partial demolition of the building with the equipment being relocated to the remaining portion until the housing development project is approved; 2) a standalone structure for the T- mobile Tower and temporary parking uses until the housing development project is approved; 3) a standalone structure for the T-mobile Tower and temporary storage uses until the housing development project is approved. Conclusion The City’s Notice is highly disappointing. After what we thought was a productive meeting on September 11 where the parties agreed to cooperate and communicate on a plan of action, the City unilaterally sends a Notice (to a vacant, fenced building) with an unreasonable timeline, without any attempt to contact the owners or their representatives, and threatening fines and jail time for noncompliance. The City’s surprise Notice is the opposite of a good faith attempt at cooperation. We hope to avoid an appeal and chart path forward together with the City. However, we need confirmation that the City will provide flexibility and work collaboratively with ownership on the items discussed above. We look forward to resolving the outstanding issues. Very truly yours, PATTERSON & O’NEILL, PC _______________________________ Brian O’Neill Item 11 Attachment H - Letter from Property Owner Representative (November 7, 2025)        Item 11: Staff Report Pg. 63  Packet Pg. 203 of 489  PATTERSON & O’NEILL, PC 235 Montgomery Street, Suite 950 San Francisco, CA 94104 Telephone: (415) 907-9110 Facsimile: (415) 907-7704 www.pattersononeill.com VIA EMAIL AND U.S. MAIL Before the city council of the city of Palo Alto Mahealani Ah Yun, City Clerk Office of the City Clerk: City Hall, 7th Floor 250 Hamilton Avenue Palo Alto, CA 94301 Re: Appeal of Notice and Order to Demolish/Deconstruct and Remove Buildings Buildings Located at 531 Stanford Avenue Dear Ms. Ah Yun: This appeal is submitted pursuant to PAMC § 16.40.080 on behalf of Stanford Orion, the property manager and owner’s representative, that is subject to the attached Notice and Order. This appeal protests the following specific orders and actions, for the following reasons: 1) The Notice and Order was not properly served. The City mailed the Notice and Order to the building at 531 Stanford Avenue, which the City knows is vacant, fenced, and inaccessible building. The City did not properly serve the Notice and Order to the building owners, or their known representatives, as required by PAMC § 16.40.060. 2) The buildings at 531 Stanford do not meet the requirements for the City to order demolition. The building has already been vacated. Building can only be ordered demolished if the building is fifty percent damaged, decayed or deteriorated from its replacement value. The Notice and Order cites a number of “violations” that are inaccurate, immaterial, grossly overstated, or which have already been addressed. Further, these violations are only relevant to issues of habitability and do not establish that the building has been fifty percent damaged, decayed or deteriorated from its replacement value. 3) The Notice and Order requires the submittal of a deconstruction permit and prohibits demolition of the building. The City Code on deconstruction, PAMC § 5.24.080 clearly exempts any building that has been determined to be dangerous, structurally unsafe or otherwise hazardous to human life that is required to be abated by demolition from all Docusign Envelope ID: 4D932618-C4F7-492A-BE9F-3666ECB0E493 Item 11 Attachment I - Appeal of Notice to Demolish (October 16, 2025) (1)        Item 11: Staff Report Pg. 64  Packet Pg. 204 of 489  deconstruction requirements. Thus, the City’s demand for deconstruction is unlawful, unauthorized, and must be set aside. 4) The Notice and Order requires complete removal by May 18, 2026. This timeframe is unreasonable, including because 1) this requires removal during the wet season, which can cause delays, increases costs, and can create dangerous condition; 2) essential public health and safety equipment is located on the building and there is currently no plan in place to address this equipment; and 3) the City has delayed approval of a post-approval plan and a vacant property with no active use will continue to be a magnet for nuisance activities. The reasons for this appeal are further elaborated in the attached response to the Notice and Order. Very truly yours, PATTERSON & O’NEILL, PC _______________________________ Brian O’Neill STANFORD ORION _______________________________ Sophia Huang 531 Stanford Avenue Palo Alto, CA 94306 Docusign Envelope ID: 4D932618-C4F7-492A-BE9F-3666ECB0E493 Item 11 Attachment I - Appeal of Notice to Demolish (October 16, 2025) (1)        Item 11: Staff Report Pg. 65  Packet Pg. 205 of 489  VERIFICATION I, Sophia Huang, declare as follows: I am the appellant in this matter and am authorized to verify as to the truth of the matters stated in the appeal. I have read the foregoing appeal and know its contents. The matters stated in the appeal are true of my own knowledge from having been a representative of the owner’s of 531 Stanford for many years. I declare the foregoing matters are true and correct. Executed on November 13, 2025 ________________________ Sophia Huang Docusign Envelope ID: 4D932618-C4F7-492A-BE9F-3666ECB0E493 Item 11 Attachment I - Appeal of Notice to Demolish (October 16, 2025) (1)        Item 11: Staff Report Pg. 66  Packet Pg. 206 of 489  Page 1 of 13 CITY OF PALO ALTO PLANNING & DEVELOPMENT SERVICES 285 Hamilton Avenue, Palo Alto, California 94301 DECLARATION OF GEORGE HOYT Chief Building Official, City of Palo Alto Regarding the Conditions and Enforcement Actions at 531 Stanford Avenue, Palo Alto, California 94306 (APN: 137-01-121, 137-01-002, 137-01-003) Case No. 24PCE-00203 I. QUALIFICATIONS AND AUTHORITY I, George Hoyt, CBO, CCEO, am currently employed by the City of Palo Alto as Chief Building Official (CBO) within the Planning & Development Services Department. I hold the Certified Building Official (CBO) designation issued by the International Code Coun cil (ICC) and the Certified Code Enforcement Officer (CCEO) credential issued by the California Association of Code Enforcement Officers, representing the highest professional certifications available in the building and code enforcement disciplines. I have served in municipal building and code enforcement roles for more than two decades and have been directly responsible for the enforcement of the California Building Standards Code (CCR Title 24), and all applicable provisions of the Palo Alto Municipal Code (PAMC), including without limitation PAMC Chapte r 16. As Chief Building Official, I have statutory authority under California Health and Safety Code (H&SC) Section 17980 et seq. and the Palo Alto Municipal Code (PAMC) to determine when structures constitute dangerous or substandard buildings; to issue Notices and Orders to Repair or Abate; to post “Unsafe to Occupy” placards; to order the vacation of occupants; and —where rehabilitation is not feasible—to order demolition. I make this declaration based on my personal inspections of the subject property, my review of all building, planning, and enforcement records maintained by the City of Palo Alto, my professional training and experience, and my direct oversight of all enfo rcement proceedings related to this matter. II. PROPERTY BACKGROUND AND PERMIT HISTORY The subject property consists of three adjoining parcels located at 531 Stanford Avenue, Palo Alto, California, commonly identified by Assessor's Parcel Numbers 137-01-121, 137-01-002, and 137-01-003. The property is also referenced in various records as 520 Oxford Avenue. The buildings at this location consist of a multi-story structure originally constructed and permitted Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 67  Packet Pg. 207 of 489  Page 2 of 13 as a hotel under Residential Occupancy Classification R-1 (transient occupancy). City records indicate that there are approximately 80 lodging rooms. A thorough search of City building, planning, and permit records conducted in connection with this enforcement matter revealed a near -total absence of required permits and inspections for the subject property. City records confirm no permits or records of inspection for any of the following: • Use and Occupancy: No valid use and occupancy permit for residential apartment use; the R-1 hotel permit had expired without renewal. Any owner or authorized agent who intends to change the occupancy of a building or structure shall first obtain the required permit. (CBC 111.1.1; PAMC § 16.04.190) • Address Assignment: The buildings were being operated under the address "520 Oxford Avenue," which was never formally assigned or authorized by the City. No permits on file for an address assignment request for 520 Oxford Avenue. (CBC 502.0; PAMC § 16.04.240) • Building Alterations: No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) • Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC 105.1) • Elevator Operation: Elevator operating certifications had expired with no renewal, in violation of CCR Title 8, Section 3001. III. INITIAL INSPECTION AND VIOLATION FINDINGS — MARCH 18, 2024 After receiving information that possible code violations existed at the property, the City sent a Request to Inspect issued January 25, 2024. After the responsible parties had failed to cooperate with initial inspection efforts, despite written admissions that the buildings were being occupied for residential purposes, a Final Notice to Inspect was issued on March 11, 2024. On March 18, 2024, I, along with Fire Marshal Tamara Jasso, Code Enforcement Supervisor Elisa Vargas, and other City staff, conducted a comprehensive inspection of the buildings at 531 Stanford Avenue. The inspection commenced at 10:00 AM and concluded at 12:00 PM, covering the basement, garage, and all accessible levels and units. The March 18, 2024, inspection revealed conditions of extraordinary severity. Based upon my professional training and decades of experience as the Chief Building Official for the City, I determined that the buildings contained numerous violations constituting a substantial danger to the life, health, and safety of all occupants. The following building code violations were identified and documented, organized by building system and location. The following code violations are not intended to be a comprehensive list of all violations present at the property at the time of inspection. The violations listed below are summary of what was observed on this site visit. Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 68  Packet Pg. 208 of 489  Page 3 of 13 My findings below are based on my direct observations of the property and observations from other City staff present conducting the inspection. Other City staff reported to me the additional findings from spaces I did not enter. Their findings are largely consistent with what I observed. A. Structural Violations were documented throughout the buildings. Much of the work described below was performed without permits, inspections, or approvals, in violation of CBC 105.1 or a dangerous or substandard condition existed. • Basement — Equipment Room: Holes in walls throughout the equipment room. Partial structural deterioration — approximately 50 percent possible erosion of structural material observed in the ceiling of the equipment room. (PAMC § 16.40.020 (a)) • Basement — Storage Room: Old ceiling falling, including attached ceiling light fixtures. Suspicious growth (mold) and corrosion observed throughout the storage room. (PAMC § 16.40.020 (a), (m)) • Garage — General: Signs of water intrusion on garage ceiling consistent with ongoing moisture infiltration and building envelope failure. (PAMC § 16.40.020 (e)) • Second-Floor Exit Balcony — Structural Shoring: The second-floor exit balcony exhibited evidence of having been shored for stability, indicating awareness of a structural deficiency requiring emergency intervention. This condition constituted a potential structural failure of a required egress path. (PAMC § 16.40.020 (a)(3); CBC 105.1) • B. Mechanical and Plumbing Violations were documented throughout the buildings. Much of the work described below was performed without permits, inspections, or approvals, in violation of CBC 105.1 or a dangerous or substandard condition existed. • Basement — Equipment Room: Water heaters installed without permits and without required seismic strapping. An abandoned pool/spa boiler was present. A possible cross - connection to potable water was identified, presenting a public health risk requiring further investigation. (PAMC § 16.40.010 (p) and 16.40.020 (g)) • Basement — Equipment Room — Return Air: Return air vent was severely corroded, compromising the mechanical ventilation system. (PAMC § 16.40.010 (p) and 16.40.020 (h)) • Garage — Equipment Room #2: Corroded drain, waste, and vent (DWV) copper piping in the ceiling. Exhaust fans in deteriorated condition, falling apart. Unpermitted boiler, two unpermitted water heaters, and two unpermitted storage tanks installed without permit or inspection. Appliance exhaust venting was non-compliant. (PAMC § 16.40.010 (p) and 16.40.020 (g), (h)) • Lobby — Unpermitted Plumbing: Unpermitted plumbing piping was installed on a wall in the lobby area to supply the unpermitted commercial kitchen adjacent to Unit 500. (PAMC § 16.40.020 (g)) Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 69  Packet Pg. 209 of 489  Page 4 of 13 C. Electrical Violations were documented throughout the buildings. Much of the work described below was performed without permits, inspections, or approvals, in violation of CBC 105.1 or a dangerous or substandard condition existed. • Basement — Equipment Room: Corroded electrical wiring and equipment throughout. Open junction boxes (j-boxes) with limited or no access cover. Corrosion of electrical components in the closet. Unsafe electrical installations. Unpermitted flood light installed above counter without permit or inspection. No permanent lighting installed; temporary lighting in use that was inappropriate for the application. (PAMC § 16.40.010 (p) and 16.40.020 (f)) • Garage — Hallway: The electrical service in the garage hallway consisted of 800-ampere and 125-ampere services. Unpermitted electrical installations were present throughout. Dead conduits and open knockouts on electrical enclosures were identified — a condition that leaves energized electrical components exposed and accessible. Exposed non- metallic (NM) cable run on the ceiling at an unpermitted light fixture. Electrical wiring was observed running along and in contact with the fire sprinkler lines, creatin g a condition where a fault in the wiring could occur. Sprint telecommunications electrical equipment requiring removal was present. (PAMC § 16.40.010 (p) and 16.40.020 (f)) • Garage — General: Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions . (PAMC § 16.40.010 (p) and 16.40.020 (f)) • Garage — Restroom: Exposed electrical wiring and exposed ceiling framing in the restroom area adjacent to the garage. (PAMC § 16.40.010 (p) and 16.40.020 (f)) • Level One — Units 109–113 and 500: Unsafe electrical in each unit, including improper use of extension cords and plug strip surge protectors as a substitute for permanent wiring. (PAMC § 16.40.010 (p) and 16.40.020 (f)) • Lobby and Office: Improper use of electrical cords and cord strips throughout the lobby and office area. Unsafe electrical installations outside at the Stanford Avenue lobby entrance. (PAMC § 16.40.020 (f)) D. Egress and Life Safety Egress violations were documented throughout the buildings. Conditions affecting required means of egress — including fire-rated door assemblies, exit signage, emergency lighting, and exit pathways — were found to be non-compliant at multiple specific locations. • Basement — Stairwell (Basement to Ground Floor): The rated door in the stairwell leading from the basement to the ground floor was missing a hinge and gaskets. The door hardware was not of a listed/approved type. The door did not self -close as required. Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 70  Packet Pg. 210 of 489  Page 5 of 13 Rated doors in this stairwell were observed propped open, defeating the fire -separation function of the rated assembly. (CBC 716.2) • Basement — Storage Room: The rated door to the storage room was not properly listed or labeled. Door hardware was incorrect and not of an approved type. The door was not self-closing as required for fire-rated assemblies. (CBC 716.2) • Garage — Equipment Room #2: Minimum head clearance conditions created due to the unpermitted installation of equipment and associated piping. (CBC 1003.2) • Second Stairwell: Door hardware in the second stairwell was non-functional and would not allow the door to close. Only a deadbolt was present as door hardware, which does not satisfy egress latch requirements and cannot be operated from the egress side in an emergency. No exit signs were present in this stairwell. (CBC 1010.2 and 1013.1) • Garage — Restroom: The rated door at the restroom was non-compliant: it was propped open, bore no required labels or ratings tags, and was equipped with the wrong hardware type. No access was available to the adjacent storage closet. (CBC 716.2) • Level One — General: Blocked exits documented on Level One. No emergency lighting was present or functional on Level One. (CBC 1010.2 and 1008.1) • Unapproved Building Materials — Plastic Film: Plastic film was affixed to ceilings in residential units and to the ceiling of the Level One hallway. This is an unapproved building material that poses significant fire propagation risk and produces toxic gases when burned. (PAMC § 16.40.010 (p), 16.40.020 (b) and CBC 803.1) • Open Stairs — Corridor: Exit signage and emergency lighting in the open stairwell corridor were limited and none were found to be working. Unpermitted storage was present in this corridor, creating additional obstructions to egress. (PAMC § 16.40.010 (a), CBC 1013.1 and 1008.1) • Garage — No Exit Signage: No exit signage was present in the garage area. (CBC 1013.1) • South Corridor Door: The south corridor door was equipped with a lockable latch — hardware that does not meet fire egress requirements for a rated assembly. No rated door or frame tags were present. The installation constituted a breach of the required rated assembly. No rated doors were present on the north side of the sam e required opening, creating an unprotected opening in the fire-rated separation. (PAMC § 16.40.010 (a), CBC 1010.2 and 716.2) • Garage — Blocked Entry: The garage entrance was blocked, preventing required access and egress through this area. (PAMC § 16.40.010 (a), 16.40.020 (j), and CBC 1006.2) • Level One — Storage Closets Locked: Storage closets on Level One were locked, and the locked telecommunication room in the garage was inaccessible to inspectors. Limited access to required spaces prevented full assessment of conditions. • Level One — Units 109–113 and 500: Smoke detectors in occupied units were outdated and did not meet current code requirements. No carbon monoxide (CO) detectors were present in any unit. (CBC 907.2 and 915; California H&S § 13113.7 and 17926) Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 71  Packet Pg. 211 of 489  Page 6 of 13 • Inoperable Elevators: Elevators had expired operating certifications and were not in service, in violation of CCR Title 8, Section 3001. E. Habitability and Sanitation Habitability violations were documented in multiple areas of the buildings. • Basement — Equipment Room: Suspicious growth on the ceiling, which was visibly- assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.010 (n), and 16.40.020 (i), (m)) • Basement — Storage Room: Suspicious growth and corrosion were observed throughout the storage room, which was visibly-assessed as potentially mold. (PAMC § 16.40.010 (n) and 16.40.020 (i, m)) • Swimming Pool — Garage and Underfloor Level: The swimming pool exhibited visible mold growth at the underfloor at garage level. (PAMC § 16.40.010 (n) and 16.40.020 (i), (m)) • Buildings Generally — Vermin: Signs of vermin infestation were observed throughout the buildings. (PAMC § 16.40.010(n) and 16.40.020(i)(13). • Level One — Overcrowding Safety Concerns: Safety concerns were documented related to overcrowded living arrangements observed on Level One, consistent with inappropriate subdivision of hotel rooms for permanent residential occupancy. (PAMC § 16.40.010(l)) F. Change of Occupancy Classification and Unpermitted Construction The buildings were operating with multiple unpermitted uses and an unauthorized occupancy classification. • Unauthorized Residential Occupancy (R-2): The buildings were originally permitted as R-1 (hotel/transient occupancy) but were being operated as R-2 (non-transient residential occupancy) without permit or approval. R-2 occupancies are subject to substantially more demanding life-safety requirements — including fire sprinkler coverage, egress standards, and occupant load requirements — that these buildings had never been designed, constructed, or inspected to satisfy such an occupancy. (PAMC § 16.40.010(l)) • Level One — Units 109, 110, 111, 112, 113, and 500: All former hotel rooms had been remodeled and converted to residential non transient occupancy use without permits. Unpermitted construction in each unit included: enclosure of balconies and decks with plastic roof structures; disconnected deck drains; and installation of electric fireplaces without permit or inspection. (CBC 105.1) • Unpermitted Commercial Kitchen Adjacent to Unit 500: A commercial kitchen was constructed adjacent to Unit 500 without any permits for construction, plumbing, mechanical, or electrical systems. The presence of a commercial kitchen within a residential occupancy building, operating without a permit or health department clearance, constitutes an unauthorized change of use. (CBC 105.1) Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 72  Packet Pg. 212 of 489  Page 7 of 13 • Unpermitted Kitchen and Laundry in Garage: Unpermitted kitchen and laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non-habitable space. (CBC 105.1) • Unpermitted Office Space in Garage: An office space was constructed in the garage without permits, with unsafe electrical conditions and storage clutter presenting no clear path of travel. (CBC 105.1) • Lobby and Office Used as Living/Storage Space: The lobby and office areas were being used for storage and as a Wi-Fi area. Warming and cooking appliances were present, indicating use of these common areas beyond their permitted function. (PAMC § 16.40.010(l)) • County Health Department Records — Status Unknown: County Health Department records relevant to the property were noted as requiring further review. The operating status of applicable County Health Department permits could not be confirmed during the inspection. (California H&S § 113700 and 114437) IV. EMERGENCY NOTICE AND ORDER TO REPAIR OR ABATE — APRIL 2, 2024 Based upon the findings of the March 18, 2024, inspection, my staff issued Notices of Violation to the property owner on March 21, 2024, and March 28, 2024, identifying the unsafe and unlawful conditions observed at the property and directing the responsible parties to take corrective action. The property owner did not take the necessary steps to fully correct the violations or otherwise bring the buildings into compliance. After determining that the buildings at 531 Stanford Avenue constituted unsafe structures and substandard residential buildings presenting an immediate and substantial danger to the life, health, and safety of the occupants and the surrounding public, I issued an Emergency Notice and Order to Repair or Abate (“N&O”) on April 2, 2024, pursuant to Health and Safety Code Section 17980.6 and PAMC Chapter 16.40. The Emergency N&O formally documented all violations described above and established the following compliance deadlines. Within five business days (by April 9, 2024), the owners were required to begin remediation of all identified unlawful conditions, including submission of permit applications. The N&O further informed the responsible parties that the City had identified a short-term solution—a FIREWATCH—to allow the existing occupants to remain in residence for a period not to exceed seven calendar days, subject to strict conditions. These conditions included continuous fire watch services, restriction of all occupants to the first floor, cessation of new rentals, draining of the pool, and securing of the second and third floors. I further formally notified the responsible parties that failure to comply with the N&O would result in the immediate posting of “UNSAFE TO OCCUPY” placards on all buildings, immediate disconnection of all utilities, and criminal misdemeanor prosecution at the rate of $1,000.00 and/or up to six months in jail per day per violation, among other available remedies. Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 73  Packet Pg. 213 of 489  Page 8 of 13 V. POSTING OF "UNSAFE TO OCCUPY" PLACARD — APRIL 9, 2024 On April 9, 2024, at 5:00 PM, after confirming that the owners had failed to make the required building repairs, obtain the required permits, or otherwise bring the buildings into compliance within the time allowed, and consistent with the direction provid ed in the Emergency N&O, I caused the buildings at 531 Stanford Avenue to be posted with an “UNSAFE — DO NOT ENTER OR OCCUPY” placard pursuant to PAMC Section 16.40.070. Following issuance of the Emergency N&O, my staff issued additional Notices of Violation to the responsible parties on April 3, 2024, and April 9, 2024, reiterating the unsafe conditions at the property and the requirement to correct those violations. The responsible parties did not take the actions necessary to bring the property into compliance. From April 9, 2024, forward, the buildings were required to be locked and secured, with access permitted only during City of Palo Alto construction hours and only for the specific purpose of removing loose combustible materials and preparing the buildings for permanent closu re. The posting of the placard constituted my official determination, as Chief Building Official, that the buildings were dangerous and substandard pursuant to PAMC Sections 16.40.010 and 16.40.020, and that continued occupancy would constitute a misdemeanor criminal violation. I further provided formal notice to the responsible parties that removal of any placard prior to issuance of a Certificate of Occupancy would itself constitute a misdemeanor violation of PAMC Section 16.40.070. VI. SUBSEQUENT MONITORING AND PERIODIC INSPECTIONS (2024 –2025) Following the vacation of the buildings and posting of the placard in April 2024, Code Enforcement and Fire Department personnel conducted periodic inspections pursuant to the requirements set forth in the Fourth Notice of Violation, dated April 9, 2024, to confirm continued non-occupancy and to monitor the security and physical condition of the property. These inspections confirmed that while tenants had vacated the premises, the underlying structural and code violations remained unaddressed, permits for remediation had not been obtained, and the physical condition of the buildings continued to deteriorate. Site inspection photographs from subsequent visits —including those taken during fire service inspections (documented under Fire Service Case Numbers 6000014517 and 6000014516) depict the continued deterioration of the property: vegetation overgrowth compromising the building envelope, breaches in the chain-link fencing, debris accumulation at the entryway, and evidence of unauthorized access to the property. A mattress and bedding observed on what appears to be an exterior walkway or balcony are consistent with evidence of unauthorized habitation—a condition I directed to be investigated and addressed. Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 74  Packet Pg. 214 of 489  Page 9 of 13 City field observations further documented evidence of unauthorized tapping into the property’s irrigation line from the public water meter. This raised concerns regarding unauthorized access to utilities following the required utility disconnection and potentially indicated the presence of unauthorized occupants. No remediation, permitting, or rehabilitation work was performed by the responsible parties during the eighteen-month period from April 2024 through October 2025. The hazardous materials closure process also remained incomplete, with Hazmat Closure Permits 24HZM-00040 and 23FDP-00929 remaining open and the responsible parties submitting extension requests as late as August 19, 2025. VII. ORDER TO DEMOLISH – OCTOBER 17, 2025 On October 17, 2025, I issued a Notice and Order to Demolish/Deconstruct and Remove the Buildings Located at 531 Stanford Avenue (the “Demolition N&O”), pursuant to H&SC Section 17980.6 and PAMC Chapter 16.40. My determination that demolition is required i s based on my finding that the buildings meet all three independent mandatory demolition criteria established by PAMC Section 16.40.050(c). Each criterion is addressed in detail below. A. First Criterion: Buildings Are Fifty Percent or More Damaged, Decayed, or Deteriorated Based upon my comprehensive assessment of the condition of the buildings at 531 Stanford Avenue—informed by my personal inspection on March 18, 2024, eighteen months of post - vacation monitoring, review of all enforcement and permit records, and my professi onal expertise as a Certified Building Official —it is my expert opinion that the buildings are fifty percent or more damaged, decayed, or deteriorated relative to their replacement value. This determination is based on the cumulative assessment of the following conditions: • Failed fire protection systems requiring complete replacement: The fire sprinkler and fire alarm systems throughout all buildings are dilapidated, corroded, and non - functional, with no maintenance records. These systems cannot be repaired in place and require complete removal and replacement throughout all buildings. The cost of fire protection system replacement alone is substantial. • Severely corroded electrical and plumbing systems: Electrical wiring, conduit, panels, plumbing pipes, and fixtures throughout the buildings exhibit severe corrosion, caused in part by exposure to improperly stored hazardous materials. This corrosion is not localized—it is systemic and affects all buildings. Complete replacement of the electrical and plumbing systems throughout all buildings is required, as repair of individual corroded components is neither feasible nor code compliant. • Structural deterioration requiring emergency shoring: The second-floor exit balcony required emergency shoring at the time of the March 18, 2024 inspection, indicating a structural failure that was not simply a maintenance issue but a fundamental load-bearing Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 75  Packet Pg. 215 of 489  Page 10 of 13 deficiency. Structural rehabilitation of this element requires engineering analysis, permitting, and construction work that cannot be accomplished through surface repair. • Extensive unpermitted construction with unknown compliance status throughout all building systems: Because none of the extensive modifications throughout the buildings were permitted, inspected, or approved, the actual structural, fire, electrical, and plumbing condition cannot be fully determined without physical demolition of finished assemblies. The presence of unknown, uninspected construction means that the apparent condition significantly understates the actual extent of deficiencies. In my professional judgment, the scope of unpermitted work and the inability to fully assess its condition without demolition is itself a significant factor in the fifty-percent determination. • Eighteen months of documented post -vacation deterioration: From April 2024 through October 2025, the buildings were not maintained, heated, or protected from the elements. Vegetation overgrowth compromised the building envelope; moisture intrusion accelerated deterioration of building systems; the security perimet er was breached; and all pre-existing conditions worsened. Buildings that are red-tagged, unoccupied, and unmaintained deteriorate rapidly, and the eighteen-month deterioration period significantly worsened the already critical conditions documented on March 18, 2024. Taking into account the cumulative replacement cost of: (1) complete fire protection system replacement; (2) complete electrical system replacement; (3) complete plumbing system replacement; (4) structural reconstruction of the exit balcony and assessment and remediation of unpermitted structural work; (5) removal and reconstruction of unpermitted construction throughout all building areas; (6) egress system reconstruction; (7) mold remediation; and (8) hazardous materials remediation it is my professional determination that the cost of rehabilitation exceeds fifty percent of the replacement value of the structures, satisfying the first demolition criterion under PAMC Section 16.40.050(c). • B. Second Criterion: Buildings Cannot Be Repaired to Eliminate the Violations It is my professional opinion that the buildings at 531 Stanford Avenue cannot be repaired, in any conventional sense of that term, to eliminate the violations documented herein and bring the Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 76  Packet Pg. 216 of 489  Page 11 of 13 buildings into compliance with applicable codes. The scope of work required to achieve compliance constitutes reconstruction rather than repair, for the following reasons: • Complete replacement of fire protection, electrical, and plumbing systems throughout all buildings • Structural reconstruction of the second-floor exit balcony • Removal and reconstruction of unpermitted work throughout all building areas • Egress system reconfiguration to meet R-2 occupancy requirements • Compliance with R-2 life-safety standards rather than the originally permitted R-1 occupancy The cumulative scope of these required activities—complete system replacement, structural reconstruction, interior demolition and rebuilding, egress reconfiguration, and occupancy classification upgrade—is, in my professional judgment, indistinguishable from demolition and reconstruction of the buildings. Rehabilitation is therefore not a meaningful option. C. Third Criterion: Buildings Constitute Fire Hazards in Violation of Applicable Codes It is my professional opinion that the buildings at 531 Stanford Avenue constitute fire hazards in violation of PAMC §§ 16.40.010(p) & 16.40.020(c), and, based on the opinion of Fire Marshall Jasso, PAMC Title 15 and the California Fire Code. These violations include the following conditions: • Failed fire sprinkler and alarm systems • Plastic film affixed to ceilings and stairways that rapidly propagates fire • Blocked or non-functional egress routes • Elevated combustible storage creating excessive fire load • Corroded electrical systems creating ignition risk • Missing emergency lighting and exit signage In my more than twenty years of municipal building enforcement experience, the buildings at 531 Stanford Avenue present some of the most extensive and severe code violations I have encountered. The combination of failed fire protection systems, extreme fir e load, unapproved fire-propagating materials in egress paths, and blocked exits creates conditions under which any fire could rapidly become fatal to any person present. These conditions cannot be effectively remediated short of complete removal of the structures. VIII. CONDITIONS OF DEMOLITION N&O The Demolition N&O established the following compliance deadlines: Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 77  Packet Pg. 217 of 489  Page 12 of 13 (1) Submission of a complete deconstruction permit application no later than November 17, 2025; and (2) Removal of the buildings and securing of the parcel no later than May 18, 2026. These deadlines were established after careful consideration of the time required to complete necessary pre-construction activities, including hazardous materials closure, utility disconnection, Bay Area Air Quality Management District (BAAQMD) J -number acquisition, regulated tree surveys, grading and excavation permits, and a pre -construction conference with all required City departments. I am aware that on November 7, 2025, the property owner’s legal representative transmitted a written response to the Demolition N&O, and that on November 13, 2025, an appeal was filed with the City Clerk pursuant to PAMC Section 16.40.080 on behalf of Stanford Orion, the property manager and owner’s representative. I have reviewed those submissions. With respect to the argument that deconstruction is not required pursuant to PAMC Section 5.24.080, I directed City staff and the City Attorney’s Office to review the argument in good faith, and I acknowledge that the exemption for dangerous buildings is be applicable. Therefore, any deconstruction efforts will be voluntary. However, I cannot, and do not, concede the underlying determination that these buildings must be demolished. The evidence of dangerous and unsafe conditions is overwhelming, well documented, and supported by multiple inspections conducted over a period of nearly two years. IX. PROFESSIONAL OPINION AND CONCLUSION Based upon my personal inspections of the property, my review of all relevant building and enforcement records, my professional training as a Certified Building Official, and my decades of experience in California municipal building regulation, it is my pr ofessional opinion that the buildings located at 531 Stanford Avenue, Palo Alto, California, constitute dangerous, unsafe, and substandard structures within the meaning of H&SC Section 17980 et seq. and PAMC Chapter 16.40. The scale and severity of the violations documented —encompassing structural deficiencies, life-safety system failures, unauthorized construction affecting all major building systems, unauthorized occupancy classification, sanitation hazards, and the absence of required permits and inspections spanning many years—is among the most extensive I have encountered in my professional career. The buildings meet all three independent mandatory demolition criteria under PAMC Section 16.40.050(c), as set forth in Section VII above. Demolition is not only warranted but required by law. Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 78  Packet Pg. 218 of 489  Page 13 of 13 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration is based upon my personal knowledge, professional training, and experience. Executed on: _______________________________ _____________________________________________ George Hoyt, CBO, CCEO Chief Building Official Planning & Development Services Department, City of Palo Alto 285 Hamilton Avenue, Palo Alto, California 94301 (650) 329-2605 Item 11 Attachment J - Declaration of George E. Hoyt, Chief Building Official v2        Item 11: Staff Report Pg. 79  Packet Pg. 219 of 489  1 of 9 CITY OF PALO ALTO PLANNING & DEVELOPMENT SERVICES — CODE ENFORCEMENT 285 Hamilton Avenue, Palo Alto, California 94301 DECLARATION OF ELISA VARGAS Code Enforcement Supervisor, City of Palo Alto Regarding Enforcement History, Compliance Record, and Current Status at 531 Stanford Avenue, Palo Alto, California 94306 (APN: 137-01-121, 137-01-002, 137-01-003) Case No. 24PCE-00203 I. QUALIFICATIONS AND AUTHORITY I, Elisa Vargas, am the Code Enforcement Supervisor for the City of Palo Alto Planning & Development Services Department. I have served in municipal code enforcement and building inspection roles for nine years, including extensive service with the City of Palo Alto. I hold the Certified Code Enforcement Officer (CCEO) designation and other professional certifications recognized in the California code enforcement field. In my role as Code Enforcement Supervisor, I am responsible for the management and overs ight of all code enforcement cases, including the direction of individual code enforcement officers, coordination with other City departments (including the Building Department and Fire Department), and the administration of all enforcement proceedings from initial complaint through resolution. I have direct and personal knowledge of the enforcement case involving the property at 531 Stanford Avenue, Case No. 24PCE-00203 (the "Case"). I supervised and personally participated in the enforcement actions described herein from the case's inception through the present. This declaration is based upon my personal observations during field inspections, my review of all case records (correspondence, inspection reports, administrative citations, and related documents maintained in City enforcement files), and my professional training and experience in California municipal code enforcement. II. CASE INITIATION AND PRELIMINARY INVESTIGATION Case No. 24PCE-00203 was opened by the Palo Alto Code Enforcement Division in January 2024, upon receipt of information indicating that the property at 531 Stanford Avenue was being used for residential occupancy without the requisite permits and that numerous modifications to the buildings had been made without building permits. A preliminary r eview of City building and planning records confirmed that no permits had been issued for any of the reported modifications and that no use and occupancy certificati on existed for the current use of the buildings. Item 11 Attachment K - Declaration of Elisa Vargas, Code Enforcement Manager v2        Item 11: Staff Report Pg. 80  Packet Pg. 220 of 489  2 of 9 A comprehensive review of City permit records confirmed a complete absence of permits for the following uses and activities: • Use and Occupancy: No valid use and occupancy permit for residential apartment use; the R-1 hotel permit had expired without renewal. Any owner or authorized agent who intends to change the occupancy of a building or structure shall first obtain the required permit. (CBC 111.1.1; PAMC § 16.04.190) • Address Assignment: The buildings were being operated under the address "520 Oxford Avenue," which was never formally assigned or authorized by the City. No permits on file for an address assignment request for 520 Oxford Avenue. (CBC 502.0; PAMC § 16.04.240) • Building Alterations: No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) • Pool Operation: No permits for pool construction, modification, or operation. (CBC 105.1). On January 25, 2024, Lead Code Enforcement Officer Brian Reynolds issued a formal “Request to Inspect” to Aurora Rising Inc. / Atlas Star, the identified responsible party, via Certified Mail No. 7014 2120 0001 4340 4290. That letter set a deadline of February 5, 2024, for the responsible parties to contact the City to schedule a comprehensive inspection. The letter cited the following code provisions: • CBC R105.1 — Permits Required: Any owner or authorized agent who intends to construct, enlarge, alter, repair, move, demolish, or change the occupancy of a building or structure, or to install, enlarge, alter, repair, convert, or replace any electrical, gas, mechanical, or plumbing system, shall first obtain the required permit. • CBC § 114.1 — Unlawful Acts: It shall be unlawful for any person, firm, or corporation to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building, structure, or equipment regulated by this code in conflict with or in violation of any of its provisions. • PAMC § 16.04.225 — Violations: It is unlawful for any person to violate any provision or to fail to comply with any requirement of PAMC Chapter 16.04. Each separate day or portion thereof during which any violation occurs shall constitute a separate offense. Violators are subject to administrative enforcement pursuant to PAMC Chapters 1.12 and 1.16 and criminal enforcement pursuant to PAMC Chapter 1.08. • PAMC §§ 18.01.030 and 18.01.080 — Compliance with Zoning Regulations Required: No land shall be used, and no facility, structure, or building shall be erected, constructed, enlarged, altered, moved, or used in any district except in accordance with the regulations established by the zoning title. Item 11 Attachment K - Declaration of Elisa Vargas, Code Enforcement Manager v2        Item 11: Staff Report Pg. 81  Packet Pg. 221 of 489  3 of 9 Despite the January 25, 2024, Request to Inspect and the stated deadline of February 5, 2024, the responsible parties did not contact the City to schedule the required inspection. Written communications received from the responsible parties during this period included admissions that the property was being used for residential living purposes, which created both an obligation for the City to conduct a life-safety inspection and an urgent basis for action. Following this failure to cooperate, I assumed direct supervisory oversight of the case and escalated the enforcement approach. III. FINAL NOTICE TO INSPECT — MARCH 11, 2024 On March 11, 2024, I issued a “Final Notice to Inspect” (“Final Notice”) under my authority as Code Enforcement Supervisor, transmitted to the responsible parties via Certified Mail No. 7014 2120 0001 4340 4481, with copies to Chief Building Official George Hoyt and Fire Marshal Tamara Jasso. This notice advised the responsible parties that the City had received written admissions confirming residential use of the property and that City Code Enforcement staff required an immediate inspection to verify the absence of immediate life and safety hazards. The Final Notice stated unambiguously that failure to cooperate could result in the City obtaining a judicial inspection warrant, 24-hour advance notice to tenants, and immediate interruption of utility services. The Final Notice set a deadline of March 14, 2024, at 5:00 PM. This deadline was not met. However, arrangements were ultimately made for an inspection to proceed on March 18, 2024. IV. FIRST NOTICE OF VIOLATION — MARCH 21, 2024 Following the comprehensive inspection conducted on March 18, 2024, by myself, Chief Building Official Hoyt, and Fire Marshal Jasso, I coordinated preparation and issuance of the 1st Notice of Violation, dated March 21, 2024, transmitted via personal service, posting on subject property, and Certified Mail No. 7018 3090 0001 0801 1115, addressed to Aurora Rising Inc./Atlas Star LLC. The 1st Notice of Violation was signed by Chief Building Official Hoyt, with copies to the City Attorney's Office, Fire Marshal Jasso, and Dana Kennedy, attorney for the responsible party. The 1st Notice of Violation documented the full scope of violations identified during the March 18, 2024, inspection, which are set forth in detail in the Declaration of Chief Building Official Hoyt and the Declaration of Fire Marshal Jasso. In summary, those violations included: • Dilapidated and missing emergency exit signage and emergency lighting throughout the buildings. • Dilapidated fire sprinkler and fire alarm systems, with no documentation of required testing, inspection, or maintenance. • Unconfirmed records of testing for fire sprinklers and fire alarm systems, rendering the systems unreliable for emergency response. • High combustible storage throughout all buildings; improper hazardous material storage creating corrosive environments; severely corroded electrical and plumbing systems. Item 11 Attachment K - Declaration of Elisa Vargas, Code Enforcement Manager v2        Item 11: Staff Report Pg. 82  Packet Pg. 222 of 489  4 of 9 • Plastic film affixed to ceilings in some units and in exit stairways, creating an extreme fire propagation hazard. • Unpermitted construction — shoring of the 2nd floor exit balcony for stability; potential structural failure of required egress path. • Unpermitted remodeling of all hotel rooms and throughout the buildings, including unauthorized enclosure of decks, patios, and addition of roof coverings. • Unpermitted construction in electrical systems, mechanical systems, and plumbing throughout all buildings. • Blocked egress on the Stanford Avenue side and throughout the interior; non - functioning and missing egress exits including missing and inoperable fire -rated doors. • Exposed mold growth in the basement; signs of vermin infestation; swimming pool with visible mold growth, no current Santa Clara County permits or clearances. • Inoperable elevators with expired operating certifications. • Unauthorized change of occupancy from R-1 (hotel) to R-2 (residential) without permit or approval. The 1st Notice of Violation set the following compliance deadlines: 1. By Friday, March 22, 2024, at 5:00 PM: Fire watch services required to be in place and monitoring the building. The City conducted an inspection at the compliance deadline time to confirm. 2. By Monday, March 25, 2024, at 2:00 PM: (a) All tenants to vacate the 2nd and 3rd floors of all buildings with access restricted; (b) Smoke detectors and carbon monoxide detectors provided to all units and common occupied areas; (c) All deadbolts and paddle lock latches removed from required exit fire-rated doors; (d) All unpermitted barriers removed from exit pathways; (e) Names and addresses of all tenants in all buildings provided to the City. 3. By Tuesday, March 26, 2024, at 5:00 PM: Pool water to be tested for chemical content and a strategy/schedule submitted for draining the pool no later than March 29, 2024. V. SECOND NOTICE OF VIOLATION — MARCH 28, 2024 A follow-up inspection conducted by City Code Enforcement and the Palo Alto Fire Department at 5:00 PM on March 22, 2024, confirmed that fire watch services were in place. A second follow-up inspection on March 25, 2024, at 2:00 PM confirmed partial compliance with the immediate life-safety corrections required by the 1st Notice of Violation: tenants had vacated upper floors, smoke and carbon monoxide detectors had been installed, deadbolts and barriers had been removed from required exits, and names and contact information for all tenants had been provided. Item 11 Attachment K - Declaration of Elisa Vargas, Code Enforcement Manager v2        Item 11: Staff Report Pg. 83  Packet Pg. 223 of 489  5 of 9 Despite this partial progress, I issued the 2nd Notice of Violation on March 28, 2024, cited under PAMC §§ 16.40.010, 16.40.020, Chapter 9.56, and Chapter 1.12, setting a next compliance deadline of Tuesday, April 2, 2024, at 5:00 PM, to confirm the draining of all pool water. The 2nd Notice of Violation also reiterated the full list of outstanding building violations that had not yet been addressed and advised the responsible parties that they remained subject to all potential enforcement consequences. VI. EMERGENCY NOTICE AND ORDER TO REPAIR OR ABATE — APRIL 2, 2024 Having determined, in coordination with Chief Building Official Hoyt, that the condition of the buildings at 531 Stanford Avenue constituted a continuing immediate danger to occupants and the public, I worked with CBO Hoyt to prepare and serve the Emergency Notice and Order to Repair or Abate ("Emergency N&O"), dated April 2, 2024, signed by CBO Hoyt and delivered via posting, first-class mail, and Certified Mail No. 7018 3090 0001 0801 1146, addressed to Aurora Rising Inc./Atlas Star and citing PAMC §§ 15.04.010, 16.40.010(a)(n)(p), 16.40.020(i)(j)(l)(m); CFC §§ 107.3, 311.2.2, 311.3; CBC § 105.1; CRC § R113.1; and CCR Title 8 § 3001. The Emergency N&O established a compliance deadline of April 9, 2024, and formally notified the responsible parties, all tenants, and interested parties of: (1) the City's determination that the buildings were dangerous and substandard; (2) the obligation to commence remediation within five business days; (3) the availability of the temporary Firewatch solution to allow continued occupancy for up to seven calendar days; and (4) the right of each tenant to relocation benefits under California Health and Safety Code Section 17975 et seq. and PAMC Chapter 9.68. On the same date, April 2, 2024, I coordinated the posting and service of the Notice to Tenants required by California Health and Safety Code Section 17975.1(c), which documented the relocation benefits owed to each displaced tenant on a per-unit basis: • Return of security deposits • Two months’ fair market rent (ranging from $4,766 for studio units to $8,022 for three - bedroom units under State law) • Utility security deposit: $50.00 • Local renter relocation assistance under PAMC Chapter 9.68: ranging from $7,971.16 for studio units to $19,358.57 for three or more-bedroom units, with additional assistance available for tenants 60 years of age or older, disabled persons, or households with minors VII. THIRD NOTICE OF VIOLATION AND ADMINISTRATIVE CITATIONS — APRIL 3, 2024 On April 3, 2024, following the emergency inspection conducted on April 1, 2024, which confirmed that fire watch services had been discontinued without authorization from March 31 through April 1, 2024, I issued the 3rd Notice of Violation under case numbe r 24PCE-00203, cited under PAMC §§ 15.04.010, 15.04.040, 15.04.070, 15.04.130, 16.40.090(a)(b); CFC § 901.7; Item 11 Attachment K - Declaration of Elisa Vargas, Code Enforcement Manager v2        Item 11: Staff Report Pg. 84  Packet Pg. 224 of 489  6 of 9 CBC § 114.1. This notice established a compliance deadline of Friday, April 5, 2024, at 12:00 PM, and documented the issuance of two administrative citations: 4. Administrative Citation No. TJ040324 (issued by Fire Marshal Jasso): $500.00 for the unauthorized discontinuation of fire watch services for the 24-hour period from March 31, 2024, at 5:00 PM through April 1, 2024, at 5:00 PM, in violation of PAMC Sections 15.04.010, 15.04.130, 15.04.140, and 15.04.070, and CFC Section 901.7. 5. Administrative Citation No. BA0040324 (issued by me as Code Enforcement Supervisor): $5,000.00 ($500.00 × 10 days) for failure to provide physical addresses for all identified tenants as required by the March 25, 2024, compliance deadline of the 1st Notice of Violation, in violation of PAMC §§ 16.40.010, 16.40.020, Chapter 9.56, and Chapter 1.12. This citation further advised that the $500.00 daily fine would continue to accrue until a compliant list was submitted. I also noted in the 3rd Notice of Violation that pool water test results had been submitted by attorney Isaac Weiner on March 31, 2024, and that the results indicated chlorine levels too high for safe discharge to the sanitary system. The responsible parties were directed to retest and provide updated results to the City. VIII. FOURTH NOTICE OF VIOLATION AND BUILDING POSTING — APRIL 9, 2024 On April 9, 2024, I issued the 4th Notice of Violation, establishing a compliance deadline of Friday, April 12, 2024, at 5:00 PM. That notice cited 2021 IPMC Appendix A (boarding standards) and PAMC § 16.04.010, and confirmed the results of follow-up inspections conducted on April 5 and April 9, 2024: • All tenants had vacated the 2nd and 3rd floors of all buildings and access was restricted. • All unpermitted installed barriers in exit pathways were continuing to be removed. • Pool water levels were on schedule for 100% water removal by April 12, 2024. • Tenants were no longer residing in the buildings (confirmed April 9, 2024). • Efforts were underway for the removal of personal belongings and loose combustible items. The 4th Notice of Violation also formalized the agreement reached with the responsible parties and their legal representative at the April 9, 2024 on -site meeting, specifying the conditions under which fire watch services could be discontinued, the required permanent closure steps to be completed by April 17, 2024, the requirement for periodic inspections by Code Enforcement and Fire Department to confirm continued non-occupancy, and the requirement for a Hazardous Materials Closure Permit by April 12, 2024 at 5:00 PM. Also on April 9, 2024, at 5:00 PM, CBO Hoyt ordered the buildings to be posted with "UNSAFE — DO NOT ENTER OR OCCUPY" placards pursuant to PAMC Section 16.40.070. From that date, Item 11 Attachment K - Declaration of Elisa Vargas, Code Enforcement Manager v2        Item 11: Staff Report Pg. 85  Packet Pg. 225 of 489  7 of 9 the buildings were required to be locked and secured at all times, with access permitted only during construction hours for the specific purpose of completing permanent closure activities. IX. POST-VACATION MONITORING AND ONGOING ENFORCEMENT (2024 –2025) Following the vacation of the buildings in April 2024, Code Enforcement Division maintained periodic oversight of the subject property pursuant to the direction of CBO Hoyt and as documented in the enforcement record. Field observations during this period documented conditions of concern: • Continued deterioration and vegetation overgrowth on the Stanford Avenue frontage, compromising the building envelope. • Damage to and unauthorized openings in the perimeter chain link fencing, indicating unauthorized access. • Debris accumulation in the entry area of the building. • Evidence of an unauthorized tap into the property's irrigation supply line from the public water meter, potentially indicating the presence of unauthorized occupants. • A mattress, pillow, and bedding observed on the floor of what appeared to be an exterior walkway or balcony area, consistent with potential unauthorized occupancy. These observations were documented and shared with CBO Hoyt and Fire Marshal Jasso. Throughout 2024 and into 2025, Code Enforcement continued to monitor the required permanent closure activities. No remediation, permitting, or rehabilitation work was performed by the responsible parties. The hazardous materials closure process was the sub ject of multiple communications between the City, the Fire Department, and the responsible parties, with certain hazmat closure work remaining incomplete as late as August 2025. Hazmat Closure Permits 24HZM-00040 and 23FDP-00929 remained open, with the responsible parties submitting extension requests as late as August 19, 2025. X. NOTICE AND ORDER TO DEMOLISH AND OWNER RESPONSE (2025) I worked closely with CBO Hoyt in the preparation of the Notice and Order to Demolish/Deconstruct and Remove the Buildings ("Demolition N&O"), dated October 17, 2025, issued pursuant to H&SC § 17980.6 and PAMC Chapter 16.40. I confirmed service of the Demolition N&O and the associated Certified Mail Receipt (USPS Tracking No. 9589 0710 5270 2033 2917 42). I further confirmed in writing to the responsible parties' attorney Brian O’Neill from Patterson & O’Neill, PC, that the 15-day appeal period would run from October 29, 2025. On November 7, 2025, the firm of Patterson & O'Neill, PC , submitted a written response to the Demolition N&O raising objections including: (1) improper service; (2) the claim that the buildings do not meet the fifty-percent deterioration threshold; (3) the claim that Item 11 Attachment K - Declaration of Elisa Vargas, Code Enforcement Manager v2        Item 11: Staff Report Pg. 86  Packet Pg. 226 of 489  8 of 9 deconstruction requirements do not apply to dangerous buildings; and (4) the claim that the May 18, 2026 removal deadline is unreasonable. On November 13, 2025, a formal Appeal of the Demolition N&O was filed with the City Clerk by Stanford Orion (property manager and owner's representative), represented by attorney Brian O'Neill of Patterson & O'Neill, PC, and executed by property manager So phia Huang. The appeal raises the same four issues as the November 7 response letter. XI. PROFESSIONAL OPINION AND CONCLUSION Based upon my nine years of municipal code enforcement experience — including direct personal involvement in every significant enforcement action taken at 531 Stanford Avenue from January 2024 through the present — it is my professional opinion that this case represents one of the most significant and complex code enforcement matters I have encountered in my career. The scope of the violations was extraordinary; the habitability and life safety hazards were real, severe, and well-documented; and the displacement of long-term tenants was a serious and adverse consequence compelled by the conditions created by the property owner, not by any punitive intent on the part of the City. Throughout this enforcement action, City staff endeavored to work collaboratively with the responsible parties — providing multiple opportunities for voluntary compliance, working to identify short-term solutions that would allow tenants to remain in place while remediation was arranged, and communicating clearly at every step about what was required, why it was required, and what the consequences of noncompliance would be. The record of this case — fourteen separate enforcement communications over less than three months in early 2024, followed by nearly eighteen months of ongoing monitoring and coordination — reflects a sustained and good-faith effort by the City to achieve a resolution that protected public safety while giving the responsible parties every reasonable opportunity to comply. The Notice and Order to Demolish was issued only after eighteen months of post -vacancy monitoring confirmed that no rehabilitation, permitting, or remediation work was undertaken by the responsible parties, and that the buildings continued to deteriorate. The City remains committed to achieving a lawful resolution that results in the safe and complete removal of these dangerous structures and the restoration of this property to a condition that is safe for the surrounding community. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration is based upon my personal knowledge, professional training, and experience. Executed on: _______________________________ _____________________________________________ Item 11 Attachment K - Declaration of Elisa Vargas, Code Enforcement Manager v2        Item 11: Staff Report Pg. 87  Packet Pg. 227 of 489  9 of 9 Elisa Vargas, CCEO Code Enforcement Supervisor Planning & Development Services Department, City of Palo Alto 285 Hamilton Avenue, Palo Alto, California 94301 (650) 885-8565 Item 11 Attachment K - Declaration of Elisa Vargas, Code Enforcement Manager v2        Item 11: Staff Report Pg. 88  Packet Pg. 228 of 489  CITY OF PALO ALTO PALO ALTO FIRE DEPARTMENT 250 Hamilton Avenue, Palo Alto, California 94301 DECLARATION OF TAMARA JASSO Fire Marshal, City of Palo Alto Fire Department Regarding Fire and Life Safety Conditions and Enforcement Actions at 531 Stanford Avenue, Palo Alto, California 94306 (APN: 137-01-121, 137-01-002, 137-01-003) Case No. 24PCE-00203 / Fire Service Case Nos. 6000014517 & 6000014516 I. QUALIFICATIONS AND AUTHORITY I, Tamara Jasso, am the duly appointed Fire Marshal for the City of Palo Alto Fire Department. In that capacity, I exercise the statutory authority of the fire code official under the California Fire Code (CFC), the Palo Alto Municipal Code (PAMC), includi ng PAMC Chapter 15.04 and related provisions, and applicable National Fire Protection Association (NFPA) standards adopted by reference. My responsibilities encompass fire prevention inspections, enforcement of the California Fire Code and local fire ordinances, hazardous materials regulation, review of fire protection systems including automatic sprinkler systems and fire alarm systems, and the administration of fire watch programs. I have served as a fire prevention professional in the City of Palo Alto for many years and have conducted hundreds of commercial, residential, and mixed-use occupancy inspections. I hold certifications relevant to fire prevention, inspection, hazardous materials regulation, and fire investigation. This declaration is based upon my personal observations during multiple inspections of the subject property, review of fire department records including Fire Service Case Nos. 6000014517 and 6000014516, my profes sional training and experience, and my direct involvement in all fire-related enforcement activities at this location. II. FIRE AND LIFE SAFETY CONDITIONS IDENTIFIED — MARCH 18, 2024 I participated in the joint inspection of the premises at 531 Stanford Avenue conducted on March 18, 2024, commencing at 10:00 AM, together with Chief Building Official George Hoyt, Code Enforcement Supervisor Elisa Vargas, and other City personnel. The fi re and life safety conditions I personally observed and documented on that date represent some of the most severe violations of the California Fire Code I have encountered in a multi -occupancy residential setting during my career. My findings are described below by category, with specific locations identified for each violation. A. Fire Sprinkler and Fire Alarm System Deficiencies Item 11 Attachment L - Declaration of Tamara Jasso, Fire Marshal v2        Item 11: Staff Report Pg. 89  Packet Pg. 229 of 489  The buildings at 531 Stanford Avenue are of a size and occupancy type that require both automatic fire sprinkler systems and fire alarm systems under the California Fire Code and applicable NFPA standards. The inspection revealed the following: • Basement — Equipment Room — Corroded Sprinkler Head: A corroded fire sprinkler head was documented in the basement equipment room. This physical evidence of corrosion at a specific sprinkler head is consistent with systemic corrosion of the entire sprinkler distribution system and indicates that the sprinkler system in this building has not been maintained, tested, or replaced as required by the CFC. A corroded sprinkler head may fail to activate in a fire, or may rupture prematurely, in either case failing to provide the life-safety protection for which it was installed. (CFC § 311.2.2; CFC Appendix I101.2)) • Garage — Hallway — Wiring on Sprinkler Lines: Electrical wiring was observed running along and in physical contact with the fire sprinkler supply lines in the garage hallway. This condition is dangerous for two reasons: (1) an electrical fault in the wiring could cause physical damage to the sprinkler piping, resulting in a water supply failure at a critical distribution point serving upper floors; and (2) electrical current conducted through metallic sprinkler piping can accelerate corrosion of the system, compromising its long-term reliability. (CFC § 311.2.2; CFC Appendix I101.2) • Level One — Units 109, 110, 111, 112, 113, and 500 — No Sprinkler Coverage: No fire sprinklers were present inside the residential units. These units had been converted from hotel rooms to permanent residential apartments — a higher-risk occupancy classification — without any fire protection system upgrade, permitting, or inspecti on. The absence of sprinkler coverage in residential units, combined with the failure of the overall building sprinkler system, leaves occupants with no automatic fire suppression protection whatsoever. (CFC § 311.2.2) • Buildings Generally — Dilapidated Fire Sprinkler Systems: The fire sprinkler systems throughout all buildings were in a dilapidated condition with clear evidence of corrosion, physical damage, and functional compromise. No documentation of required testing, inspection, or maintenance by a licensed fire protection contractor could be produced by the responsible parties. (CFC § 311.2.2) • Buildings Generally — Dilapidated Fire Alarm Systems: The fire alarm systems were in a dilapidated and unreliable condition, with no verifiable documentation of current testing or inspection. (CFC § 901.6.3) • No Fire Protection System Permits or Records: City records confirmed a complete absence of any permits, inspection records, or certifications for the fire sprinkler or fire alarm systems at this property. The responsible parties could not produce records confirming that these systems had ever been tes ted, inspected, or certified. Given the combination of dilapidated systems, specific physical evidence of corrosion at documented locations, and the complete absence of testing records, I determined on March 18, 2024 that the fire protection systems at 531 Stanford Avenue could not be Item 11 Attachment L - Declaration of Tamara Jasso, Fire Marshal v2        Item 11: Staff Report Pg. 90  Packet Pg. 230 of 489  relied upon to function in the event of a fire emergency, placing all building occupants at severe and immediate risk of death or injury. B. Egress, Exit, and Corridor Deficiencies — Location-Specific Findings Deficiencies in the means of egress were documented at multiple specific locations throughout the buildings. Each location is described below. The cumulative effect of these deficiencies is that there was no reliable path of egress available to any building occupant in the event of a fire. (CFC § § 1032.1 - 1032.2) • Basement — Stairwell (Basement to Ground Floor): The rated door in the stairwell providing egress from the basement to the ground floor was missing a hinge and gaskets. The door hardware was not of a listed or approved type. The door did not self - close as required for fire-rated assemblies. Rated doors in this stairwell were propped open, directly defeating the fire and smoke separation function of the rated assembly. A rated door that is propped open provides no fire or smoke compartmentalization and allows fire and toxic gases to spread from the basemen t into the rest of the building through the only stairwell egress from that level. (CFC 1026.3; CFC 1010.2.2; CFC § 311.2.2; CRSC Sec 12-10-200 (b) & (c)) • Basement — Storage Room: The rated door to the storage room was not properly listed or labeled — required markings confirming the door assembly's fire rating were absent. The door hardware was of an incorrect type not approved for rated door assemblies. The door was not self-closing as required. (CFC 1026.3; CFC 1010.2.2; CRSC § 12-10-200 (b) & (c)) • Second Stairwell: The door hardware in the second stairwell was non-functional: the door would not close properly. The only hardware present was a deadbolt, which does not constitute compliant egress latch hardware and cannot be operated from the egress side in an emergency without a key. The presence of a deadbolt as the sole door hardware on an exit door means that an occupant attempting to escape through this stairwell in a fire could be unable to open the door. No exit signs were present in this stairwell, meaning occupants in a smoke-filled corridor could not locate this exit route. (CFC § 1010.2; CFC § 1010.27; CFC § 1013.1) • Garage — Restroom — Rated Door: The rated door at the restroom was propped open, bore no required labels or fire rating markings, and was equipped with incorrect hardware that did not satisfy fire-rated door assembly requirements. (CFC § 1026.3; CFC § 1010.2.2) • South Corridor Door — Breach of Rated Assembly: The south corridor door was equipped with a latchable latch that does not meet fire egress requirements for a rated assembly. No rated door or frame tags were present on this assembly, and the condition of the installation constituted a breach of the requi red fire-rated wall separation. Critically, no rated doors were present on the north side of the same required rated opening — meaning the rated wall assembly was completely unprotected at this corridor crossing, allowing fire and smoke to pass freely through what should be a fire barrier. This is among the most serious egress deficiencies observed during the Item 11 Attachment L - Declaration of Tamara Jasso, Fire Marshal v2        Item 11: Staff Report Pg. 91  Packet Pg. 231 of 489  inspection, as it eliminates the compartmentalization that rated assemblies are designed to provide. (CFC § 1020.2; CFC § 1104.17) • Open Stairs — Corridor: Exit signage and emergency lighting in the open stairwell corridor were limited, and none were working at the time of inspection. Non- functioning emergency lighting and exit signage in a stairwell means that occupants attempting to use this primary egress path in a fire — when smoke and power loss are likely — would be unable to see or navigate the stairs safely. (CFC § 1013.1; CFC § 1032.4; CFC § 1032.10) • Level One — General: Exits were blocked on Level One. No emergency lighting was present or functional on Level One. (CFC § 1032.2; CFC § 1104.5) • Garage — No Exit Signage: No exit signage was present anywhere in the garage area. Occupants in the garage — including persons using the unpermitted kitchen, laundry, or office — could not identify exit routes in a fire. (CFC § 1013.1) • Level One — Units 109–113 and 500 — No Rated Unit Doors or Gaskets: The rated doors on individual residential units — which are required to slow the spread of fire between units and the corridor — were non-compliant. No rated door and no door gasket were present on Unit 109, and the same condition was noted in Units 110 through 113 and Unit 500. Gaskets on rated doors serve a critical function: they prevent smoke infiltration under the door, which is a primary cause of death in residential fires. The absence of both the rated door and gasket means that fire and smoke can enter these residential spaces immediately upon any fire in the corridor (CFC § 1020.2; CBC Table 716.1(2); CFC § 1104.17). • Buildings Generally — Deadbolts and Latchable Latches on Exit Doors: Throughout the buildings, deadbolts and latchable latches were found on required exit fire -rated doors. Under California fire code egress requirements, exit doors must be operable from the egress side without a key, special knowledge, or special effort. These conditions directly prevent occupants from escaping a fire and were required to be immediately corrected (CFC § 1010.2; CFC § 1032.7) C. Combustible Storage and Fire Load Hazards Combustible materials were stored throughout the buildings in quantities and configurations that created significantly elevated fire load conditions. Elevated fire load accelerates fire spread and dramatically reduces the time available for occupant evacuation. (CFC § 311.3) • Garage — Unpermitted Storage of Flammable Liquids and LP Tanks: Paint thinner, unlabeled fuel containers, and liquid propane (LP) tanks were being stored in the garage and Level One area without permits, proper labeling, or required secondary containment. Flammable liquids and LP tanks stored without proper controls re present acute fire and explosion hazards. In a fire scenario, these materials would dramatically accelerate fire spread and create explosion risk that would be fatal to any building occupants and first responders in the area. (CFC § 3201; CFC § 6109) Item 11 Attachment L - Declaration of Tamara Jasso, Fire Marshal v2        Item 11: Staff Report Pg. 92  Packet Pg. 232 of 489  • Garage — Propane and Oil Tank: A propane tank and an oil tank were present in the garage area without permits or required safety measures. (CFC § 6109) • Garage — Restroom — High Combustible Storage: High combustible storage was present in the unpermitted storage room located in the restroom area of the garage. High combustible load in an enclosed space with a non-compliant rated door creates conditions under which fire can develop rapidly without any barrier to prevent spread. (CFC § 315.3.4) • Garage / Level One — Combustible Decorative Items: Combustible plastic pictures and artificial (fake) trees were present in the garage and Level One areas. Plastic decorative items burn rapidly, produce intense heat, and release toxic gases, contributing to both fire spread and smoke toxicity. (CFC § 807.2) • Level One — Plastic Film on Hallway Ceiling: Plastic film was present on the ceiling of the Level One hallway — a required means of egress. Plastic film is an unapproved building material that burns rapidly, produces toxic gases, and presents extreme fire propagation risk. A fire igniting this material in an exit hallway would immediately contaminate the primary exit path with fire and toxic smoke, trapping occupants who must pass through the hallway to reach an exit. (CFC § 314.3; CFC § 311.3) • Level One — Units — Plastic Film on Unit Ceilings: Plastic film was affixed to the ceilings of residential units (documented in Unit 109 and noted as the same condition in Units 110–113 and 500). The presence of this material throughout occupied residential units means that any fire starting or spreading into a unit would be immediately accelerated by the ceiling material, with no barrier between the burning ceiling and the unit occupants below. (CFC § 311.3; CFC § 807.2) • Buildings Generally — High Combustible Storage: High combustible storage was documented throughout all buildings, including in the garage restroom, lobby and office area, and open corridor spaces, creating elevated fire load conditions throughout all areas of the buildings. (CFC § 311.3) D. Hazardous Materials Storage Hazardous materials were stored at multiple locations throughout the buildings without permits, secondary containment, or compliance with hazardous materials handling requirements, in violation of PAMC Section 17.12.010. • Basement — Equipment Room — Pool Chemicals: Pool chemicals were present in the equipment room without required secondary containment. Improper storage of pool chemicals creates risk of chemical release, corrosive damage to surrounding building systems, and potential toxic gas generation in a fire or spill event. A possible cross- connection to the potable water supply was also identified and flagged for investigation. (PAMC § 17.12.020 (c); CFC § 5001) • Garage — Hydraulic Fluid: An empty hydraulic fluid container was present in the garage hallway, indicating prior storage of hydraulic fluid in this location without required permits or controls. (PAMC § 17.12.010; PAMC 17.04.020) Item 11 Attachment L - Declaration of Tamara Jasso, Fire Marshal v2        Item 11: Staff Report Pg. 93  Packet Pg. 233 of 489  • Garage — Flammable/Combustible Liquids and LP Tanks: Paint thinner, unlabeled fuel containers, and LP tanks were stored in the garage and Level One area without permits, proper labeling, or required secondary containment. (PAMC § 17.12.010; PAMC 17.04.020) • Telecommunications Rooftop Equipment: Hazardous materials associated with telecommunications cell tower infrastructure located on the roofs of the buildings were identified as requiring specialized closure procedures under the City's Hazardous Materials Closure Plan requirements. No Hazardous Materials Business Plan or related permits had been obtained for the storage or handling of any hazardous materials at the property. III. IMPOSITION AND ADMINISTRATION OF FIRE WATCH REQUIREMENT As a consequence of the dilapidated and unreliable condition of the fire sprinkler and alarm systems, combined with the occupied status of the buildings at the time of the March 18, 2024, inspection, I determined that immediate fire watch services were required pursuant to the California Fire Code and my authority as Fire Marshal. Fire watch services are required under the CFC when fire alarm or sprinkler systems are fully or partially out of service, or when other special hazards exist, because they provide a minimum level of life safety protection when automatic systems cannot be relied upon. On March 21, 2024, in the 1st Notice of Violation, the responsible parties were given until March 22, 2024, at 5:00 PM to have fire watch services in place and monitoring the building. My office provided Fire Watch Information documentation to the responsible parties specifying the requirements, including that fire watch personnel conduct continuous patrols at not less than 30-minute intervals, maintain a patrol log, have two means of communication, be knowledgeable about the building floor plan and hazards, and submit daily fire watch logs by email to the Palo Alto Fire Department. On March 22, 2024, at 5:00 PM, I conducted a follow-up inspection and confirmed that fire watch services were in place and that the fire watch personnel were completing the necessary logs required to be submitted to my department on a weekly basis. I also identified the emergency path of egress and directed it to be made available for inspection on March 25, 2024. Unauthorized Discontinuation of Fire Watch — April 1, 2024 On April 1, 2024, at approximately 10:45 AM, Code Enforcement conducted an emergency inspection and confirmed that fire watch services were not in place, having been discontinued on March 31, 2024, at 5:00 PM without authorization from the City. The unauthorized discontinuation of fire watch services left an occupied building with no functioning fire protection systems and no continuous monitoring for a period of approximately 24 hours — a condition I determined constituted a life safety emergency. I conducted a follow-up inspection on April 1, 2024, at 2:00 PM, confirmed the absence of fire watch coverage, and confirmed the absence of required fire watch logs for the period of March Item 11 Attachment L - Declaration of Tamara Jasso, Fire Marshal v2        Item 11: Staff Report Pg. 94  Packet Pg. 234 of 489  31 through April 1. Fire watch services were reinstated with a new service provider on April 1, 2024, at 5:00 PM after the new provider's application and logs were submitted and approved. In connection with this violation, Administrative Citation No. TJ040324 was issued on April 3, 2024, imposing a $500.00 fine for the unauthorized 24-hour gap in fire watch coverage. IV. CONDITIONS FOR TERMINATION OF FIRE WATCH — APRIL 9, 2024 At a meeting held at the premises on April 9, 2024, attended by myself, Code Enforcement Supervisor Elisa Vargas, attorney for property manager Sophia Y. Huang, Isaac Weiner, and Property Manager Sophia Y. Huang, I communicated the conditions under which f ire watch services could be discontinued without requiring immediate vacation of the building. These conditions included: 1. All residents must have vacated the building, and no person shall sleep or spend extended periods of time in the buildings. 2. Any person working in the building under authorization shall be required to call 911 in the event of an emergency or fire. 3. High fire loads must be removed from the buildings, or documentation that functioning fire sprinklers and alarms have been tested and certified must be provided by April 12, 2024, at 5:00 PM. 4. Updated keys must be provided and placed in the existing Knox Box to allow Fire Department access. I further communicated that the responsible parties were required to obtain a Hazardous Materials Closure Permit from the Palo Alto Fire Department no later than April 12, 2024 , at 5:00 PM, and to work with Fire Department hazardous materials personnel to develop and implement a closure plan, including the removal of hazardous materials associated with the telecommunications cell towers on the rooftops. V. FIRE DEPARTMENT MONITORING AND ONGOING CONCERNS (2024–2025) Following the vacation of the buildings on or around April 9, 2024, the Palo Alto Fire Department continued to monitor the subject property as part of its ongoing code enforcement obligations. Fire Service Case Nos. 6000014517 and 6000014516 document conti nued Fire Department involvement in inspection and monitoring activities at the property during the post-vacation period. During post-vacation monitoring, Fire Department personnel observed conditions consistent with potential unauthorized reoccupation of the premises, including a mattress and bedding positioned on an exterior walkway or balcony area visible during an inspection. Continued vegetative overgrowth, damaged and opened sections of perimeter chain link fencing, and evidence of tapping into the property's irrigation line further suggested the possibility of unauthorized persons entering and utilizing the property. These observations are of particular concern from a fire safety standpoint: vacant buildings with compromised fire protection Item 11 Attachment L - Declaration of Tamara Jasso, Fire Marshal v2        Item 11: Staff Report Pg. 95  Packet Pg. 235 of 489  systems are especially vulnerable to fire when unauthorized occupants are present, as such persons may use open flame for heat, cooking, or lighting. The hazardous materials associated with the T-Mobile and Sprint/T-Mobile telecommunications equipment on the buildings' rooftops remained a significant concern throughout the post - vacation period. Hazardous materials closure permit 24HZM-00040 and fire department closure permit 23FDP-00929 were the subject of ongoing coordination between the Fire Department and the responsible parties. The responsible parties submitted a permit extension/reactivation request as late as August 19, 2025, indicating that complete closure of the hazardous materials component had not been achieved as of that date. VI. EXPERT ANALYSIS — FIRE AND LIFE SAFETY BASIS FOR DEMOLITION It is my professional opinion as Fire Marshal, based upon my personal observations, review of fire department records, and professional training and experience, that the fire and life safety conditions at 531 Stanford Avenue provide independent and suffici ent grounds for demolition under each of the three criteria of PAMC Section 16.40.050(c). A. Fire Hazard in Violation of Applicable Codes The buildings at 531 Stanford Avenue constitute fire hazards in violation of PAMC Title 15 and the California Fire Code through the following conditions, each of which independently violates applicable fire code provisions: • Failed fire protection systems (PAMC § 15.04.010; CFC §§ 107.3, 311.2.2): The buildings are required to have functional automatic sprinkler and alarm systems. These systems are dilapidated, corroded, and non-functional with no maintenance records. Buildings with non-functional fire protection systems are, by definition, fire hazards under applicable codes. • Plastic film on ceilings and in exit stairways (CFC § 311.3): The presence of plastic film as a building material in exit stairways is particularly dangerous because: (1) plastic film burns at an extreme rate and cannot be extinguished by building occupants; (2) it produces toxic gases that incapacitate occupants bef ore they can evacuate; and (3) it is located specifically in the exit pathways that occupants must use to escape, meaning that a fire igniting this material in an exit stairway would trap and kill the occupants it was meant to protect. • Blocked and non-functional egress (CFC 1032.2): Blocked egress routes, missing and non-functional fire-rated doors, and deadbolt locks on fire exits mean that if a fire breaks out in these buildings, occupants cannot escape. This is the fundamental fire safety failure that makes these buildings imminently dangerous — not just code non- compliant. Item 11 Attachment L - Declaration of Tamara Jasso, Fire Marshal v2        Item 11: Staff Report Pg. 96  Packet Pg. 236 of 489  • High combustible storage and elevated fire load (CFC 301.1; CCR, Title 19, Division 1, §3.14 (Fire Hazard); CCR, Title 19, Division 1, §3.19 (a)-(g) (Housekeeping)): The accumulated combustible materials throughout the buildings create conditions under which any fire would spread rapidly and overwhelm any response before occupants could evacuate. • Corroded electrical systems (CFC § 603.2.1): Severely corroded electrical wiring, conduit, and equipment throughout the buildings represents an ongoing ignition risk. Corroded electrical systems are a leading cause of building fires, particularly in buildings that have been unoccupied and unmaintained. • Missing emergency lighting and exit signage (CFC 1032.10, CFC 1032.4): In a fire with power loss and smoke, occupants rely on emergency lighting and exit signage to locate and navigate exits. The absence of these systems means that any fire in these buildings would immediately become unsurvivable for occupants who cannot locate an exit. B. Cannot Be Repaired to Eliminate Fire Violations It is my expert opinion that the fire and life safety violations at 531 Stanford Avenue cannot be remediated through repair, and that compliance with fire code requirements would require effectively rebuilding the buildings. The basis for this opinion is: • Complete fire protection system replacement required: The fire sprinkler and alarm systems throughout all buildings are dilapidated and non-functional. These systems cannot be repaired in place; they require complete removal and replacement, including all piping, heads, alarm devices, control panels, and ancillary equipment throughout all buildings. This is a reconstruction-level undertaking, not a repair. • Plastic film requires demolition of finished assemblies to remove: The plastic film is applied to building surfaces and incorporated into the structure. Complete removal requires physical demolition of the surfaces to which it is attached, which is in effect interior demolition of all affected areas — which include exit stairways throughout the buildings. • Egress system reconstruction: The egress system requires reconstruction, not repair: fire-rated doors and frames must be replaced or reconstructed; exit pathways must be physically reconfigured to eliminate blockages; and the entire emergency lighting and exit signage system must be replaced throughout all buildings. • Unknown condition of building systems requires demolition to assess: Because extensive unpermitted construction was performed in all building areas, the actual condition of walls, ceilings, and structural assemblies adjacent to fire protection and electrical systems cannot be assessed without physical demolition. The scope of required remediation cannot be determined until the buildings are opened up — at which point the work required will be indistinguishable from rebuilding. C. Contribution to Fifty Percent Deterioration Finding Item 11 Attachment L - Declaration of Tamara Jasso, Fire Marshal v2        Item 11: Staff Report Pg. 97  Packet Pg. 237 of 489  From a fire protection standpoint, the following conditions contribute materially to the overall fifty percent deterioration determination made by Chief Building Official Hoyt: • Complete fire protection system replacement cost: The cost of replacing the fire sprinkler and alarm systems throughout all buildings — including system design, permitting, installation, testing, and certification — is substantial and constitutes a significant portion of the total system replacement costs that support the fifty percent determination. • Eighteen months of deterioration in vacant buildings: Vacant, unmaintained buildings deteriorate rapidly, particularly with respect to fire protection systems, which require regular testing, maintenance, and certification. Systems that were already dilapidated in March 2024 have continued to deteriorate through April 2024–October 2025 without any maintenance, significantly worsening the conditions documented at the initial inspection. VII. PROFESSIONAL OPINION AND CONCLUSION It is my professional opinion as Fire Marshal of the City of Palo Alto, based upon my personal observations, my review of fire department records, and my professional training and experience, that the buildings at 531 Stanford Avenue presented, throughout the period of their occupation and continuing through the present, fire and life safety hazards of the most serious nature. The combination of failed sprinkler and alarm systems, blocked egress, combustible storage, corroded electrical systems, non-functioning fire-rated assemblies, missing emergency lighting and signage, and structural deficiencies with the second-floor balcony creates conditions that pose substantial danger of fire, would prevent safe evacuation in the event of a fire and provide an unsafe environment for first responders/firefighters when responding to a fire or other emergency. The combination of dilapidated and unreliable fire protection systems, an extreme combustible fire load, unapproved fire -propagating materials in egress pathways, blocked and non-functional exits, severely corroded electrical systems, and the complete absence of any fire safety permits or inspection records created conditions under which any fire in these buildings could rapidly become fatal to occupants. The unauthorized discontinuation of fire watch services on March 31, 2024, — leaving an occupied building with no functioning fire protection systems and no monitoring coverage for 24 hours — represents an act of extraordinary recklessness that endangered the lives of all occupants and neighbors. The imposition of the fire watch requirement was not a punitive measure but a minimum necessary life safety protection, and its unauthorized removal is a matter I regard with the utmost seriousness. The demolition of these buildings is supported by this declaration and is consistent with my professional assessment that the accumulated fire and life safety deficiencies cannot be addressed short of complete removal of the structures. The buildings meet the fire hazard criterion under PAMC Section 16.40.050(c) and independently satisfy the grounds for demolition under that section. In my career as a fire prevention professional, these buildings represent the most serious fire and life safety hazards I hav e encountered. Item 11 Attachment L - Declaration of Tamara Jasso, Fire Marshal v2        Item 11: Staff Report Pg. 98  Packet Pg. 238 of 489  I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration is based upon my personal knowledge, professional training, and experience. Executed on: _______________________________ _____________________________________________ Tamara Jasso Fire Marshal, City of Palo Alto Fire Department 250 Hamilton Avenue, Palo Alto, California 94301 (650) 329-2184 Item 11 Attachment L - Declaration of Tamara Jasso, Fire Marshal v2        Item 11: Staff Report Pg. 99  Packet Pg. 239 of 489  1 of 163 Photographic Evidence of Code Violations at 531 Stanford Avenue Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 100  Packet Pg. 240 of 489  2 of 163 Section I - 531 Stanford Avenue Exterior and Perimeter Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 101  Packet Pg. 241 of 489  3 of 163 PAMC Violation: Photo of the mailbox located at 531 Stanford Avenue, Palo Alto, CA 94306. Indicating where residents could have their packages delivered. The buildings were being operated under the address "520 Oxford Avenue," which was not formally assigned or authorized by the City of Palo Alto. No permits on file for an address assignment request for 520 Oxford Avenue. (CBC § 502.0; PAMC § 16.04.240) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 102  Packet Pg. 242 of 489  4 of 163 PAMC Violation: Overgrown Vegetation located on Stanford Avenue. PAMC 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section PAMC § 8.08.010. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 103  Packet Pg. 243 of 489  5 of 163 PAMC Violation: Unauthorized installation of safety cage. Knox box not accessible from exterior. PAMC 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 104  Packet Pg. 244 of 489  6 of 163 PAMC Violation: Indication that no access to Knox Box was possible by emergency fire personnel in the event of an emergency. PAMC § 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 105  Packet Pg. 245 of 489  7 of 163 PAMC Violation: Overgrown vegetation that is also encroaching Public Right of Way PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 106  Packet Pg. 246 of 489  8 of 163 PAMC violation: Overgrown vegetation encroaching on sidewalk. PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010. (8) The existence of any branches or foliage which interfere with visibility on, or free use of, or access to, or obstruct public vehicular or pedestrian travel on any portion of any street improved for vehicular or pedestrian travel so as to be a nuisance under Section 8.04.050(f). (9) The existence of hedges or dense thorny shrubs and plants on any street or part thereof so as to be a nuisance under Section 8.04.050(g). (10) The Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 107  Packet Pg. 247 of 489  9 of 163 existence of shrubs and plants more than two feet in height in any street, measured above top of curb grade so as to be a nuisance under Section 8.04.050(h). Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 108  Packet Pg. 248 of 489  10 of 163 Overgrown Vegetation and unauthorized security cage installed. PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010. PAMC § 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 109  Packet Pg. 249 of 489  11 of 163 PAMC Violation: Overgrown Vegetation PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 110  Packet Pg. 250 of 489  12 of 163 PAMC Violation: Overgrown Vegetation PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 111  Packet Pg. 251 of 489  13 of 163 PAMC Violation: Overgrown Vegetation and unauthorized security cage installed. PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010. PAMC § 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 112  Packet Pg. 252 of 489  14 of 163 PAMC Violation: Overgrown vegetation on public right of way PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 113  Packet Pg. 253 of 489  15 of 163 PAMC Vioaltion: Extension cord hanging from roof, landing onto the balcony. Unathorized basrrier made of wire mesh. PAMC §16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 114  Packet Pg. 254 of 489  16 of 163 PAMC Vioaltion: Extension cord hanging from roof, landing onto the balcony. Unathorized basrrier made of wire mesh. PAMC §16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 115  Packet Pg. 255 of 489  17 of 163 PAMC Violation: Unpermitted installation of venting for commercial laundry room in basement, discharging directly onto the sidewalk at 520 Oxford Ave, Palo Alto, CA 94306. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 116  Packet Pg. 256 of 489  18 of 163 PAMC Violation: Unpermitted installation of venting for commercial laundry room in basement, discharging directly onto the sidewalk at 520 Oxford Ave, Palo Alto, CA 94306. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 117  Packet Pg. 257 of 489  19 of 163 PAMC Violation: Unauthorized mailbox indicating 520 Oxford Ave, Palo Alto, CA 94306. Unpermitted Cage. The buildings were being operated under the address "520 Oxford Avenue," which was never formally assigned or authorized by the City of Palo Alto. No permits on file for an address assignment request for 520 Oxford Avenue. (CBC 502.0; PAMC § 16.04.240) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 118  Packet Pg. 258 of 489  20 of 163 PAMC Violation: Unauthorized mailbox indicating 520 Oxford Ave, Palo Alto, CA 94306. Unpermitted Cage. The buildings were being operated under the address "520 Oxford Avenue," which was never formally assigned or authorized by the City of Palo Alto. No permits on file for an address assignment request for 520 Oxford Avenue. (CBC 502.0; PAMC § 16.04.240) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 119  Packet Pg. 259 of 489  21 of 163 PAMC Violation: Unauthorized Entrance located at Oxford Ave, Palo Alto, CA 94306. The buildings were being operated under the address "520 Oxford Avenue," which was never formally assigned or authorized by the City of Palo Alto. No permits on file for an address assignment request for 520 Oxford Avenue. (CBC § 502.0; PAMC § 16.04.240) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 120  Packet Pg. 260 of 489  22 of 163 Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 121  Packet Pg. 261 of 489  23 of 163 Section II: 531 Stanford Avenue Interior Floors 1, 2, 3, & Roof Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 122  Packet Pg. 262 of 489  24 of 163 PAMC Violation(s): Interior walkway showing the unpermitted shoring of the second level floor above. Mesh atrium was built off the 2nd floor. PAMC 16.40.010 Dangerous building defined (d) Whenever any portion or member or appurtenance thereof is likely to fall, or to become detached or dislodged, or to collapse and thereby injure persons or damage property. Second-Floor Exit Balcony — Structural Shoring: The second-floor exit balcony exhibited evidence of having been shored for stability, indicating awareness of a structural deficiency requiring emergency intervention. This condition constituted a potential s tructural failure of a required egress path. (PAMC § 16.40.020 (a)(3)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 123  Packet Pg. 263 of 489  25 of 163 PAMC Violation: Blocking Emergency Egress PAMC 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Door hardware was not of a listed/approved type. The door did not self-close as required. Rated doors in this stairwell were observed propped open, defeating the fire-separation function of the rated assembly. (CBC 716.2) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 124  Packet Pg. 264 of 489  26 of 163 PAMC Violation: Unpermitted installation of screen door. Blocking emergency egress path. PAMC 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 125  Packet Pg. 265 of 489  27 of 163 PAMC Violation: Unpermitted construction of Sunroom. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 126  Packet Pg. 266 of 489  28 of 163 PAMC Violation: Unpermitted installation of egress door. PAMC § 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 127  Packet Pg. 267 of 489  29 of 163 PAMC Violation: Unpermitted installation of egress door. PAMC § 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 128  Packet Pg. 268 of 489  30 of 163 PAMC Violation: Unpermitted construction, blocked egress, dangerous conditions. PAMC § 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Second-Floor Exit Balcony — Structural Shoring: The second-floor exit balcony exhibited evidence of having been shored for stability, indicating awareness of a structural deficiency requiring emergency intervention. This condition constituted a potential s tructural failure of a required egress path. (PAMC § 16.40.020 (a)(3)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 129  Packet Pg. 269 of 489  31 of 163 PAMC Violation: View of Unpermitted Mesh Atrium, corridor, and unpermitted windows. PAMC § 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Second-Floor Exit Balcony — Structural Shoring: The second-floor exit balcony exhibited evidence of having been shored for stability, indicating awareness of a structural deficiency requiring emergency intervention. This condition constituted a potential s tructural failure of a required egress path. (PAMC §16.40.020 (a)(3)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 130  Packet Pg. 270 of 489  32 of 163 PAMC Violation: Exterior View of unpermitted construction of corridor connecting the buildings. Second-Floor Exit Balcony — Structural Shoring: The second-floor exit balcony exhibited evidence of having been shored for stability, indicating awareness of a structural deficiency requiring emergency intervention. This condition constituted a potential s tructural failure of a required egress path. (PAMC § 16.40.020 (a)(3)) No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 131  Packet Pg. 271 of 489  33 of 163 PAMC Violation: Exterior view of removal of unpermitted construction of corridors connecting the buildings. Blocked off door at 2nd Floor. Top view of unpermitted Mesh Atrium. PAMC §16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 132  Packet Pg. 272 of 489  34 of 163 PAMC Violation: View of the Unpermitted structure that was removed. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 133  Packet Pg. 273 of 489  35 of 163 PAMC Violation: Unpermitted construction; blocking doorways that lead to high falls with no stairs. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 134  Packet Pg. 274 of 489  36 of 163 PAMC Violation: Rooftop view of empty pool. Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC § 105.1) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 135  Packet Pg. 275 of 489  37 of 163 PAMC Violation: Rooftop View of unpermitted Gazebo structure. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. This includes accessory structures like gazebos that exceed 120 square ft. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 136  Packet Pg. 276 of 489  38 of 163 PAMC Violation: Unpermitted plastic film installed. Located throughout the buildings; installed in rooms and hallways. Plastic Film: Plastic film was affixed to ceilings in residential units and to the ceiling of the Level One hallway. This is an unapproved building material that poses significant fire propagation risk and produces toxic gases when burned. (PAMC Section 16.40.020(b) and CBC 803.1) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 137  Packet Pg. 277 of 489  39 of 163 PAMC Violation: Electrical Panel Not labeled properly. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 138  Packet Pg. 278 of 489  40 of 163 PAMC Violation: Removal of unpermitted Gazebo Structure and ramp. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. This includes accessory structures like ramps and patio flooring that exceed 120 square ft. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 139  Packet Pg. 279 of 489  41 of 163 PAMC Violation: Removal of unpermitted Gazebo Structure and ramp. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. This includes accessory structures like ramps and patio flooring that exceed 120 square feet. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 140  Packet Pg. 280 of 489  42 of 163 PAMC Violation: Unpermitted construction of ramp and patio flooring. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. This includes accessory structures like ramps and patio flooring that exceed 120 square feet. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 141  Packet Pg. 281 of 489  43 of 163 PAMC Violation: Unpermitted Ramp No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. This includes accessory structures like ramps and patio flooring that exceed 120 square feet. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 142  Packet Pg. 282 of 489  44 of 163 PAMC Violation: Unsafe Electrical Panel – No panel cover installed. Panel was live. Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 143  Packet Pg. 283 of 489  45 of 163 PAMC Violation: Unpermitted construction. Penetration of walls. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 144  Packet Pg. 284 of 489  46 of 163 PAMC Violation: Unpermitted construction. Penetration of wall. Unknown repairs. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 145  Packet Pg. 285 of 489  47 of 163 PAMC Violation: Unpermitted construction. Unfinished open penetration causing fire concerns, and ventilation discharge. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 146  Packet Pg. 286 of 489  48 of 163 PAMC Violation: Storage of combustible materials. PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 147  Packet Pg. 287 of 489  49 of 163 PAMC Violation: Storage of combustible materials. PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 148  Packet Pg. 288 of 489  50 of 163 PAMC Violation: Storage of combustible materials PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. . Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 149  Packet Pg. 289 of 489  51 of 163 PAMC Violations: Unpermitted construction that created unsafe fire conditions, unknown if it was a repair or a remodel. Unpermitted venting installed without permit or inspection. Venting was non-compliant. (PAMC § 16.40.020 (g)(h)) No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 150  Packet Pg. 290 of 489  52 of 163 PAMC Violation: Unpermitted construction that created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished Unpermitted venting installed without permit or inspection. Venting was non -compliant. (PAMC § 16.40.020 (g)(h)) No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 151  Packet Pg. 291 of 489  53 of 163 PAMC Violation: Unpermitted construction that created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished. Unpermitted venting installed without permit or inspection. Venting was non -compliant. (PAMC § 16.40.020 (g)(h)) No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 152  Packet Pg. 292 of 489  54 of 163 PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished. Unpermitted venting installed without permit or inspection. Venting was non -compliant. (PAMC § 16.40.020 (g)(h)) No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 153  Packet Pg. 293 of 489  55 of 163 PAMC Violation: Vacated room that was remodeled from temporary conditions and converted for long term residence. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 154  Packet Pg. 294 of 489  56 of 163 PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 155  Packet Pg. 295 of 489  57 of 163 PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 156  Packet Pg. 296 of 489  58 of 163 PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished Unpermitted venting installed without permit or inspection. Venting was non -compliant. (PAMC § 16.40.020 (g)(h)) No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 157  Packet Pg. 297 of 489  59 of 163 PAMC Violation: View of miscellaneous items that were repurposed from when the buildings were used as a hotel. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 158  Packet Pg. 298 of 489  60 of 163 PAMC Violation: View of miscellaneous items that were repurposed from when the buildings were used as a hotel. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 159  Packet Pg. 299 of 489  61 of 163 PAMC Violation: Unpermitted construction of conduit for unknown purpose. Left unfinished. Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 160  Packet Pg. 300 of 489  62 of 163 PAMC Violation: Unsafe electrical panel. No panel cover installed. Panel confirmed live. Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 161  Packet Pg. 301 of 489  63 of 163 Unpermitted construction for unknown purpose. Left unfinished. Unpermitted construction of wall and door. PAMC Violation: Unpermitted construction of wall and installation of unapproved door. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in viola tion of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 162  Packet Pg. 302 of 489  64 of 163 PAMC Violation: Unauthorized removal of drywall for unknown reasons. Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 163  Packet Pg. 303 of 489  65 of 163 PAMC Violation: Unpermitted door hardware, adapted to add a lock. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 164  Packet Pg. 304 of 489  66 of 163 PAMC Violation: Unpermitted door hardware, adapted to add a lock. 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 165  Packet Pg. 305 of 489  67 of 163 PAMC Violation: Improper exit signage. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 166  Packet Pg. 306 of 489  68 of 163 PAMC Violation: Improper exit signage. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 167  Packet Pg. 307 of 489  69 of 163 PAMC Violation: Improper exit signage. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 168  Packet Pg. 308 of 489  70 of 163 PAMC Violation: Unpermitted door hardware, adapted to add a lock. 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 169  Packet Pg. 309 of 489  71 of 163 PAMC Violation: Miscellaneous items impeding emergency egress. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 170  Packet Pg. 310 of 489  72 of 163 PAMC Violation: Miscellaneous items located in the “former lobby”. Room used as storage. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 171  Packet Pg. 311 of 489  73 of 163 PAMC Violation: Unsafe electrical installation of lightbulb. Fire hazard. Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 172  Packet Pg. 312 of 489  74 of 163 PAMC Violation: Unpermitted door hardware, adapted to add a lock. 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 173  Packet Pg. 313 of 489  75 of 163 PAMC Violation: Room used as storage. Represents combustible load. (CFC sec. 311.3) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 174  Packet Pg. 314 of 489  76 of 163 PAMC Violation: Blocked weather head. Unsafe electrical. Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 175  Packet Pg. 315 of 489  77 of 163 PAMC Violation: Unpermitted construction, Improper installation of A/C unit. Similar conditions present throughout all converted hotel rooms. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 176  Packet Pg. 316 of 489  78 of 163 Unsafe electrical installations in the garage area generally, including unpermitted conduit runs were installed, unsafe electrical conditions were present. (PAMC § 16.40.020) (f)) PAMC Violation: Unpermitted Construction: Installation of unpermitted conduit that is penetrating the ceiling and wall assembly. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 177  Packet Pg. 317 of 489  79 of 163 PAMC Violation: Expired Fire Extinguisher. Most of the fire extinguishers present throughout the entire buildings were expired. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 178  Packet Pg. 318 of 489  80 of 163 Section III: 531 Stanford Avenue Basement Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 179  Packet Pg. 319 of 489  81 of 163 PAMC Violation: Unpermitted installation of electric fence in basement. No exit signage is visible in garage. No exit signage was present in the garage area. (CBC 1013.1) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 180  Packet Pg. 320 of 489  82 of 163 PAMC Violation: Improper use of signage in basement/garage. No exit signage was present in the garage area. (CBC 1013.1) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 181  Packet Pg. 321 of 489  83 of 163 PAMC Violation: Unpermitted and unsafe installation of conduit. J box left in an unsafe condition. Unsafe electrical installations in the garage area generally, including unpermitted conduit runs were installed. J-Box cover missing creating unsafe conditions. (PAMC § 16.40.020) (f)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 182  Packet Pg. 322 of 489  84 of 163 PAMC Violation: Unpermitted storage areas built, false walls visible. Use of temporary electrical sources. Electrical strips and unsafe runs of electrical cords. Unsafe electrical installations in the garage area generally, including unpermitted storage areas where unsafe electrical conditions were present. (PAMC § 16.40.020) (f)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 183  Packet Pg. 323 of 489  85 of 163 PAMC Violation: Unpermitted storage areas built, false walls visible. Use of temporary electrical sources. Electrical strips and unsafe runs of electrical cords. Unsafe electrical installations in the garage area generally, including unpermitted storage areas where unsafe electrical conditions were present. (PAMC § 16.40.020) (f)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 184  Packet Pg. 324 of 489  86 of 163 PAMC Violation: Improper storage blocking access to emergency shut off. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 185  Packet Pg. 325 of 489  87 of 163 PAMC Violation: Unsafe storage conditions. High combustible loads. PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 186  Packet Pg. 326 of 489  88 of 163 PAMC Violation: Unsafe storage conditions. High combustible loads. PAMC 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 187  Packet Pg. 327 of 489  89 of 163 PAMC Violation: Unsafe storage conditions. High combustible loads. PAMC 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 188  Packet Pg. 328 of 489  90 of 163 PAMC Violation: Unsafe storage conditions. High combustible loads. PAMC § 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 189  Packet Pg. 329 of 489  91 of 163 PAMC Violation: Unsafe storage conditions. High combustible loads. PAMC § 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 190  Packet Pg. 330 of 489  92 of 163 PAMC Violation: Unpermitted installation of water heater/storage tank. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 191  Packet Pg. 331 of 489  93 of 163 PAMC Violation: Unsafe storage conditions. High combustible loads. PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 192  Packet Pg. 332 of 489  94 of 163 PAMC Violation: Unpermitted installation of commercial laundry machines. Unpermitted Laundry in Garage: Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non-habitable space. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 193  Packet Pg. 333 of 489  95 of 163 PAMC Violation: Unsafe use of chemicals associated with the unpermitted installation of commercial laundry machines. Unpermitted Laundry in Garage: Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non -habitable space. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 194  Packet Pg. 334 of 489  96 of 163 Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 195  Packet Pg. 335 of 489  97 of 163 PAMC Violation: Unsafe storage conditions. High combustible loads. PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 196  Packet Pg. 336 of 489  98 of 163 PAMC Violation: Unsafe use of chemicals associated with the unpermitted installation of commercial laundry machines. Unpermitted Laundry in Garage: Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non -habitable space. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 197  Packet Pg. 337 of 489  99 of 163 PAMC Violation: Unsafe use of chemicals associated with the unpermitted installation of commercial laundry machines. Unpermitted Laundry in Garage: Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non -habitable space. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 198  Packet Pg. 338 of 489  100 of 163 PAMC Violation: Unsafe storage conditions. High combustible loads. Unpermitted Laundry in Garage: Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non -habitable space. PAMC § 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 199  Packet Pg. 339 of 489  101 of 163 PAMC Violation: Unpermitted installation of laundry machines. This creates unsafe electrical, plumbing, and mechanical venting conditions Unpermitted Laundry in Garage: Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non-habitable space. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 200  Packet Pg. 340 of 489  102 of 163 PAMC Violation: Unapproved use of indoor bike storage. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 201  Packet Pg. 341 of 489  103 of 163 PAMC Violation: Visible corrosion on piping. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 202  Packet Pg. 342 of 489  104 of 163 PAMC Violation: Improper installation electrical wiring in metallic corrugated raceway. Unsafe electrical installations in the garage area generally (PAMC § 16.40.020) (f)) No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 203  Packet Pg. 343 of 489  105 of 163 PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Construction left unfinished. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 204  Packet Pg. 344 of 489  106 of 163 PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 205  Packet Pg. 345 of 489  107 of 163 PAMC Violation: Unknown substances stored in closed storage equipment room. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 206  Packet Pg. 346 of 489  108 of 163 PAMC Violation: Improper materials used for firestopping and unpermitted installation of romex wiring. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Unsafe electrical installations. Unpermitted flood light installed without permit or inspection. (PAMC § 16.40.020) (f)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 207  Packet Pg. 347 of 489  109 of 163 PAMC Violation: Untreated penetrations, allowing for airflow. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 208  Packet Pg. 348 of 489  110 of 163 PAMC Violation: Non-operable pull station. The fire alarm systems were in a dilapidated and unreliable condition, with no verifiable documentation of current testing or inspection, in violation of PAMC Section 15.04.010 and CFC Section 901.6.3. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 209  Packet Pg. 349 of 489  111 of 163 PAMC Violation: Unpermitted and improperly installed dilapidated lighting fixture. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 210  Packet Pg. 350 of 489  112 of 163 PAMC Violation: Description: Unpermitted construction, unsafe electrical, and structural. Unsafe storage conditions. High combustible loads. Code Violation: PAMC § 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 211  Packet Pg. 351 of 489  113 of 163 PAMC Violation: Unsafe installation of electrical receptable located resting on fire sprinkler. Unsafe electrical installations. Unpermitted receptacle installed without permit or inspection. (PAMC § 16.40.020) (f)) The fire alarm systems were in a dilapidated and unreliable condition, with no verifiable documentation of current testing or inspection, in violation of PAMC Section 15.04.010 and CFC Section 901.6.3. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 212  Packet Pg. 352 of 489  114 of 163 PAMC Violation: Unsafe storage conditions. High combustible loads. Blocking emergency egress. PAMC § 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or pr ovide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. The garage entrance was blocked, preventing required access and egress through this area. (CBC 1006.2) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 213  Packet Pg. 353 of 489  115 of 163 PAMC Violation: Improper storage of chemicals used for pool. Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC § 105.1) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 214  Packet Pg. 354 of 489  116 of 163 PAMC Violation: Improper storage of portable gas container (filled with gas) and paint thinner. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 215  Packet Pg. 355 of 489  117 of 163 PAMC Violation: Unsafe installation of electrical wires in basement. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 216  Packet Pg. 356 of 489  118 of 163 PAMC Violation: Unsafe installation of electrical wires in basement. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 217  Packet Pg. 357 of 489  119 of 163 PAMC Violation: Unsafe installation of electrical wires draped over accordion door. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 218  Packet Pg. 358 of 489  120 of 163 PAMC Violation: Unsafe installation of electrical wires in basement. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 219  Packet Pg. 359 of 489  121 of 163 PAMC Violation: Sprinkler system corroded. Corrosion visible in ceiling in friable condition. Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) The fire alarm systems were in a dilapidated and unreliable condition, with no verifiable documentation of current testing or inspection, in violation of PAMC Section 15.04.010 and CFC Section 901.6.3. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 220  Packet Pg. 360 of 489  122 of 163 PAMC Violation: Improper use of emergency egress access. Propping a door for emergency exit is unsafe. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 221  Packet Pg. 361 of 489  123 of 163 PAMC Violation: Removal of Fire Doors, creating unsafe conditions. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 222  Packet Pg. 362 of 489  124 of 163 PAMC Violation: Salt pool system. Corrosion present. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC § 105.1) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 223  Packet Pg. 363 of 489  125 of 163 PAMC Violation: Unsafe temporary light fixture used instead of permanent light source. No permanent lighting installed; temporary lighting in use that was inappropriate for the application. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 224  Packet Pg. 364 of 489  126 of 163 PAMC Violation: Unpermitted construction and unsafe penetrations created. Unknown if this was part of a remodel, repair, or abandonment of mechanical ducting. Left unfinished. Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 225  Packet Pg. 365 of 489  127 of 163 PAMC Violation: Corrosion of electrical conduit and electrical j-box. Corroded electrical wiring and equipment throughout. Open junction boxes (j-boxes) with limited or no access cover. Corrosion of electrical components in the closet. Unsafe electrical installations. (PAMC § 16.40.020) (f)) Suspicious growth on the wall, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 226  Packet Pg. 366 of 489  128 of 163 PAMC Violation: Unsafe storage of pool chemicals. Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC § 105.1) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 227  Packet Pg. 367 of 489  129 of 163 PAMC Violation: Corrosion on piping for water, electrical conduit, and walls visible in mechanical room associated with pool water conditioning system. Corroded electrical wiring and equipment throughout. Corrosion of electrical components in the closet. Unsafe electrical installations. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC § 105.1) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 228  Packet Pg. 368 of 489  130 of 163 PAMC Violation: Unsafe penetration in wall. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 229  Packet Pg. 369 of 489  131 of 163 PAMC Violation: Corrosion on piping and walls visible in mechanical room associated with pool water conditioning system. Unsafe installation of electrical cords and terminations. Corroded electrical wiring and equipment throughout. No permanent lighting installed; temporary lighting in use that was inappropriate for the application. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 230  Packet Pg. 370 of 489  132 of 163 PAMC Violation: Corrosion on piping and walls visible in mechanical room associated with pool water conditioning system. Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 231  Packet Pg. 371 of 489  133 of 163 PAMC Violation: Corrosion on piping and walls visible in electrical room. Unsafe. Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access. Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020 Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 232  Packet Pg. 372 of 489  134 of 163 PAMC Violation: Corrosion on piping and walls visible in electrical room. Unsafe. Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access. Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020 Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 233  Packet Pg. 373 of 489  135 of 163 PAMC Violation: Corrosion on piping and walls visible in electrical room. Unsafe. Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access. Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020 Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 234  Packet Pg. 374 of 489  136 of 163 PAMC Violation: Corrosion on walls visible in electrical room. Conduit leading directly into electrical panels. Mold growth on ceiling. Unsafe. Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access. Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 235  Packet Pg. 375 of 489  137 of 163 PAMC Violation: Dilapidated vent. Vermin/Rodent access. Visible feces. Vermin: Signs of vermin infestation were observed throughout the buildings. (PAMC § 16.40.010(n) and 16.40.020(i)(13). Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 236  Packet Pg. 376 of 489  138 of 163 PAMC Violation: Evidence of corrosion/causing unknown growth. Unsafe. Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 237  Packet Pg. 377 of 489  139 of 163 PAMC Violation: Deteriorated sprinkler head. The fire alarm systems were in a dilapidated and unreliable condition, with no verifiable documentation of current testing or inspection, in violation of PAMC Section 15.04.010 and CFC Section 901.6.3. Corroded Sprinkler Head: A corroded fire sprinkler head was documented in the basement equipment room. This physical evidence of corrosion at a specific sprinkler head is consistent with systemic corrosion of the entire sprinkler distribution system, and indicates that the sprinkler system in this building has not been maintained, tested, or replaced as required by the CFC. A corroded sprinkler head may fail to activate in a fire, or may rupture prematurely, in either case failing to provide the life-safety protection for which it was installed. (PAMC § 15.04.010; CFC § 311.2.2; CFC Appendix I101.2)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 238  Packet Pg. 378 of 489  140 of 163 PAMC Violation: Unpermitted installation of flood light, left unfinished. Unsafe electrical installations. Unpermitted flood light installed without permit or inspection. (PAMC § 16.40.020) (f)) No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 239  Packet Pg. 379 of 489  141 of 163 PAMC Violation: Unsafe emergency egress access blocked. 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 240  Packet Pg. 380 of 489  142 of 163 PAMC Violation: Visible corrosion is located directly in ceiling, under the pool. Unsafe electrical runs and terminations. Unsafe electrical installations. Light installed above without permit or inspection (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020 Corroded Sprinkler Head: A corroded fire sprinkler head was documented in the basement equipment room. This physical evidence of corrosion at a specific sprinkler head is consistent with systemic corrosion of the entire sprinkler distribution system, and indicates that the sprinkler system in this building has not been maintained, tested, or replaced as required by the CFC. A corroded sprinkler head may fail to activate in a fire, or may rupture prematurely, in either case failing to provide the life-safety protection for which it was installed. (PAMC § 15.04.010; CFC § 311.2.2; CFC Appendix I101.2)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 241  Packet Pg. 381 of 489  143 of 163 PAMC Violation: Visible corrosion is located directly in ceiling, under the pool. Unsafe electrical runs and terminations. Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access. Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 242  Packet Pg. 382 of 489  144 of 163 PAMC Violation: Visible corrosion is located directly in ceiling, under the pool. Unsafe electrical runs and terminations. Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access. Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 243  Packet Pg. 383 of 489  145 of 163 PAMC Violation: Visible corrosion is located directly in ceiling, under the pool. Unsafe electrical runs and terminations. Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access. Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Corroded Sprinkler Head: A corroded fire sprinkler head was documented in the basement equipment room. This physical evidence of corrosion at a specific sprinkler head is consistent with systemic corrosion of the entire sprinkler distribution system, and indicates that the sprinkler system in this building has not been maintained, tested, or replaced as required by the CFC. A corroded sprinkler head may fail to activate in a fire, or may rupture prematurely, in either case failing to provide the life-safety protection for which it was installed. (PAMC § 15.04.010; CFC § 311.2.2; CFC Appendix I101.2)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 244  Packet Pg. 384 of 489  146 of 163 PAMC Violation: Visible corrosion is located directly in ceiling, under the pool. Unsafe electrical runs and terminations. Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access. Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 245  Packet Pg. 385 of 489  147 of 163 PAMC Violation: Visible corrosion is located directly in ceiling and on wall, under the pool. Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 246  Packet Pg. 386 of 489  148 of 163 PAMC Violation: Visible corrosion is located directly in ceiling and on wall, under the pool. Unsafe electrical runs and terminations . Corroded sprinkler head. Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access. Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Corroded Sprinkler Head: A corroded fire sprinkler head was documented in the basement equipment room. This physical evidence of corrosion at a specific sprinkler head is consistent with systemic corrosion of the entire sprinkler distribution system, and indicates that the sprinkler system in this building has not been maintained, tested, or replaced as required by the CFC. A corroded sprinkler head may fail to activate in a fire, or may rupture prematurely, in either case failing to provide the life-safety protection for which it was installed. (PAMC § 15.04.010; CFC § 311.2.2; CFC Appendix I101.2)) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 247  Packet Pg. 387 of 489  149 of 163 PAMC Violation: Visible corrosion is located directly in ceiling and wall, under the pool. Unsafe electrical runs and terminations. Unsafe electrical installations. Unpermitted electrical run without permit or inspection. (PAMC § 16.40.020) (f) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 248  Packet Pg. 388 of 489  150 of 163 PAMC Violation: Visible corrosion/deterioration is located directly in ceiling and wall, under the pool. Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40 .020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 249  Packet Pg. 389 of 489  151 of 163 PAMC Violation: Visible corrosion/deterioration is located directly in ceiling, under the pool. Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 250  Packet Pg. 390 of 489  152 of 163 PAMC Violation: Visible corrosion/deterioration is located directly in ceiling, under the pool. Unsafe electrical conditions caused by corrosion. Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access. Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 251  Packet Pg. 391 of 489  153 of 163 PAMC Violation: Improper storage of hazardous materials. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 252  Packet Pg. 392 of 489  154 of 163 PAMC Violation: Unsafe installation of j-box with no cover. Confirmed to be live. No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erec t, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 253  Packet Pg. 393 of 489  155 of 163 PAMC Violation: Unsafe penetrations in walls located in a mechanical room. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 254  Packet Pg. 394 of 489  156 of 163 PAMC Violation: Improper materials used for duct venting Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 255  Packet Pg. 395 of 489  157 of 163 PAMC Violation: Improper materials used for fire penetration caulking. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 256  Packet Pg. 396 of 489  158 of 163 PAMC Violation: Broken door assembly. Many instances of similar conditions located throughout the buildings. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 257  Packet Pg. 397 of 489  159 of 163 Section IV: 531 Stanford Avenue Postings Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 258  Packet Pg. 398 of 489  160 of 163 Example of how buildings were posted. 4th Notice of Violation Posted on April 9, 2024 (Stanford Avenue side) All notices were posted in similar manner. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 259  Packet Pg. 399 of 489  161 of 163 Example of how buildings were posted. 4th Notice of Violation Posted on April 9, 2024 (Stanford Avenue side) All notices were posted in similar manner. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 260  Packet Pg. 400 of 489  162 of 163 Example of how buildings were posted. 4th Notice of Violation Posted on April 9, 2024 (Oxford Avenue side) All notices were posted in similar manner. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 261  Packet Pg. 401 of 489  163 of 163 Example of how buildings were posted. 4th Notice of Violation Posted on April 9, 2024 (Oxford Avenue side) All notices were posted in similar manner. Use of Evidence tape to confirm that no entry would be made in the future by unauthorized personnel. Item 11 Attachment M - Photographic Evidence of Code Violations at 531 Stanford Avenue        Item 11: Staff Report Pg. 262  Packet Pg. 402 of 489  City Council Staff Report From: City Clerk Report Type: ACTION ITEMS Lead Department: City Clerk Meeting Date: April 20, 2026 Report #:2604-6232 TITLE Adoption of Recommendations by the Policy & Services Committee Implementing Changes to Meeting Procedures Related to Teleconferencing, Remote Public Participation, Translation and Interpretation Assistance, and Expanded Public Outreach; CEQA Status – Not a Project. RECOMMENDATION The Policy & Services Committee recommends the City Council: 1. Decline the use of expanded alternative teleconferencing for Boards, Commissions, and Committees (BCCs), 2. Receive an update on changes to remote public participation and provide direction on the format for general public comment for City Council and Council Committee meetings, 3. Approve the Two-Way Remote Public Access Disruption Policy (Attachment A), 4. Approve the following practices as reasonable assistance for third party translation and interpretation services, and a. Arrange a space for interpreters at the meeting location, upon written request to the City Clerk at least 24 hours before the meeting, b. Provide public speakers using interpretation extra time. Staff recommends providing twice as much time for individuals using interpretation, or an amount of time determined by the presiding officer, c. Allow the public to use their own devices to access translation or interpretation devices, and d. Loan city devices to the public to access translation or interpretation services upon written request to the City Clerk at least 24 hours before the meeting. 5. Direct the City Clerk to implement the following outreach practices a. Share information about agenda notification newsletters with community groups and organizations such as neighborhood associations, non-English news media, service organizations, b. Post informational resources in the King’s Plaza and Council Chambers posting board and other public-facing City facilities with QR codes linking to the Agendas Item 12 Item 12 Staff Report        Item 12: Staff Report Pg. 1  Packet Pg. 403 of 489  webpage, newsletter sign-up page, meeting participation guide, and translation services webpage, and c. Translate the Meeting Participation Guide1 into the two most commonly spoken non-English languages as reported by the American Community Survey. EXECUTIVE SUMMARY In 2025, the California State Legislature adopted SB 707, which amended the Brown Act to modernize remote participation and expand public access to meetings. This report provides an overview of SB 707 requirements, identifies areas where the City is already compliant, and outlines recommended policy and operational updates where changes are required. The Policy & Services Committee (P&S) unanimously recommended not authorizing expanded alternative teleconferencing for BCCs, while supporting staff recommendations related to translation, outreach, and related provisions.2 Because SB 707 requires 3this report is not agendized on consent . The primary policy considerations before the City Council include whether to authorize expanded alternative teleconferencing for BCCs, how to implement remote public comment requirements, and adoption of policies and practices related to meeting disruptions, translation, and outreach. BACKGROUND The enactment of SB 707 brought notable changes to the Brown Act, the law that ensures public access and participation in local legislative body meetings. The bill is intended to modernize public meetings in light of newer technology and expand public participation and engagement. The updates concern expanded BCC teleconferencing, remote public participation, third-party translation assistance, and public outreach. Certain provisions only affect the City Council’s meetings, while others apply to all Brown Act bodies. Some requirements went into effect on January 1, 2026, but others are not operative until July 1, 2026 to give agencies time to plan implementation. The table below summarizes SB 707’s key updates and P&S’s implementation recommendations. 1 City of Palo Alto Meeting Participation Guide: https://www.paloalto.gov/files/assets/public/v/1/city-clerk/city- charterprocedures/2025-meeting-participation-guide.pdf 2 Policy & Services Committee, February 10, 2026 Action Minutes: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=85416&dbid=0&repo=PaloAlto Item 12 Item 12 Staff Report        Item 12: Staff Report Pg. 2  Packet Pg. 404 of 489  Topic Summary Applicable Meeting Bodies Effective Date BCC Expanded Alternative Teleconferencing Council could authorize BCCs to meet fully virtually for up to six months at a time. The P&S Committee did not recommend authorizing this form of teleconferencing. BCCs 1/1/26 Remote Public Participation and Public Comment SB 707 requires the City Council provide a two-way audiovisual or telephonic platform. The City’s use of Zoom for City Council, Council Committees, and BCCs exceeds this requirement. The City Council must update its practices to allow for remote general public comment by 7/1/26. Staff recommends allowing remote general public comment for Council Committees to maintain consistency across meeting bodies. P&S directed staff to evaluate dividing general public comment into two sections. In-person comments will be heard at the beginning of the meeting and remote comments will be heard at the end of the meeting. City Council 7/1/26 Disruption of Remote Public Access Policy The City Council must recess and attempt to restore remote access if Zoom is disrupted during a meeting. The City Council must adopt a disruption policy describing these procedures by 7/1/26. P&S recommended adoption of the policy (Attachment A). City Council 7/1/26 Third-Party Translation and Interpretation Assistance SB 707 requires the City Council to provide reasonable assistance to individuals receiving third-party translation and/or interpretation at meetings. It does not require the City to provide translation and/or interpretation services. P&S recommended arranging space for interpretation to occur, allotting extra public comment time for individuals using interpretation, allowing individuals to use their own devices for interpretation and loaning City devices for translation upon advance request. City Council 7/1/26 Outreach Efforts SB 707 requires cities to make reasonable efforts to encourage participation from groups that traditionally do not engage in public meetings. P&S recommends continuing existing outreach practices and enhancing transparency and accessibility by clarifying how community City Council 7/1/26 Item 12 Item 12 Staff Report        Item 12: Staff Report Pg. 3  Packet Pg. 405 of 489  members may request language assistance and participate remotely, consistent with SB 707’s intent to broaden civic engagement. ANALYSIS The following section details Brown Act changes brought by SB 707 that will affect the City and staff’s recommended implementations. The City’s current practices already satisfy or surpass some of SB 707’s requirements (detailed in Attachment B), but others will require a change in practice or policy. Expanded Alternative Teleconferencing for Eligible Subsidiary Bodies (effective January 1, 2026) Following COVID-19, the State Legislature amended the Brown Act to allow members of legislative bodies to participate in meetings remotely under specific circumstances (i.e. “just cause” or “emergency circumstances”) with fewer noticing requirements than traditional Brown Act teleconferencing. This form of teleconferencing, which does not require remote attendance locations to be published on the agenda or accessible to the public, is referred to as alternative teleconferencing. The City Council incorporated SB 707’s changes, detailed in Attachment B, to alternative teleconferencing in its most recent Procedures and Protocol Handbook update.7 SB 707 allows the City Council to authorize an additional form of remote participation, called expanded alternative teleconferencing, for eligible subsidiary bodies, a category that includes the City’s BCCs. Commissioners are permitted to use alternative teleconferencing regardless of the City Council’s decision regarding expanded alternative teleconferencing. Council Committees are not eligible because SB 707 does not permit Councilmembers to use expanded alternative teleconferencing. Expanded alternative teleconferencing would allow BCC members to attend remotely without opening their location to the public and without just cause, subject to the minimum requirements listed below. Unlike alternative teleconferencing, expanded alternative teleconferencing does not require a quorum to attend from a singular physical location and therefore could allow a fully virtual meeting. This provision is optional and requires affirmative Council action to implement. The City Council may authorize expanded alternative teleconferencing for up to six months and every six months thereafter. To authorize expanded alternative teleconferencing, the City Council must take formal action approving the expanded use of alternative teleconferencing for a period of up to six months, and include findings that Council has: Considered the circumstances of the subsidiary body, Determined that teleconferencing would enhance public access, Ensured publication of remote and physical access and comment options, and 7 City Council, February 9, 2025, Agenda Item #12; Staff Report # 2601-5874 https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=85860 Item 12 Item 12 Staff Report        Item 12: Staff Report Pg. 4  Packet Pg. 406 of 489  Determined that teleconferencing would promote attraction, retention, and diversity of eligible board or commission members. Meetings held via expanded alternative teleconferencing must meet the requirements below. The City Council may impose additional requirements but may not remove requirements. The subsidiary body must provide a staffed physical meeting location where the agenda is posted and members of the body or public may attend and participate in-person, Elected officials may not use this section to appear remotely, and Remote members must appear visibly on camera, with limited exceptions. While expanded alternative teleconferencing may improve flexibility and accessibility for BCC members, staff notes that in-person meetings provide important benefits that support the City’s public engagement goals. Face-to-face meetings facilitate stronger communication between Commissioners, staff, and community members, promote relationship-building, and allow for more dynamic public dialogue. Further, a significant expansion of alternative teleconferencing presents compliance and administrative challenges. The City has eight BCCs addressing diverse subject areas ranging from stormwater management to arts and culture. These bodies are supported by staff from multiple departments, many of whom support BCC meetings infrequently. The Brown Act’s teleconferencing requirements are complex, and expanded alternative teleconferencing adds additional procedural obligations that increase the risk of inadvertent non-compliance. The P&S Committee did not recommend authorizing expanded alternative teleconferencing for BCCs. If the City Council wishes to authorize expanded alternative teleconferencing, staff recommends that it be implemented thoughtfully and incrementally, with clear, administrable rules and defined evaluation criteria. Staff suggests beginning with a modest pilot approach. For example, Council could authorize one specific Board or Commission to conduct a limited number of fully virtual meetings within a six-month period, allowing staff and the body to evaluate impacts on public participation, meeting quality, and administrative workload before considering broader implementation. Implementation of expanded teleconferencing may require additional staff training and coordination across departments, particularly for BCCs supported by decentralized staff. Remote Public Participation and Public Comment (effective July 1, 2026) SB 707 mandates City Council meetings include an option for remote public participation and accept remote public comment via a two-way telephonic or audiovisual platform. Palo Alto already uses Zoom for its City Council, Council Committee and BCC meetings, which surpasses the new requirements. However, the City Council will have to adjust its general public comment practices. The City Council currently accepts general public comment for non-agendized items only in-person and accepts public comment on agendized items in-person and remotely. The City Item 12 Item 12 Staff Report        Item 12: Staff Report Pg. 5  Packet Pg. 407 of 489  Council must allow remote general public comment beginning on July 1, 2026. This requirement does not apply to BCCs or Council Committees. Although not mandated by SB 707, staff recommends also accepting remote general public comment at Council Committee meetings to maintain consistency across City Council meeting bodies. Staff will communicate the change to the public prior to the effective date and update agenda materials and internal practices to comply with this provision. Policy on Disruption of Remote Public Access (effective July 1, 2026) If a disruption prevents public participation through Zoom, City Council shall recess open session for at least one hour and attempt in good faith to restore service or adjourn the meeting, City Council may meet in an agendized closed session during the recess, Open session may not reconvene until at least one hour has passed or service is restored, whichever comes first, and If service is not restored, City Council may resume after adopting, by roll call vote, a finding that good faith efforts were made to restore service and that the public interest in continuing the meeting outweighs the public interest in remote access. Item 12 Item 12 Staff Report        Item 12: Staff Report Pg. 6  Packet Pg. 408 of 489  Staff from the City Clerk, City Attorney, and IT departments collaborated on the attached draft policy (Attachment A). The draft policy details the good faith efforts staff shall make to restore service, which may include: Troubleshooting platform or teleconferencing software, Resetting or replacing audiovisual equipment, Attempting alternative connection methods, Contacting necessary support staff or service providers, and/or Switching to back-up equipment or platforms, if available. The Policy & Services Committee recommended the City Council approve the attached disruption policy. Third-Party Translation and Interpretation Assistance (effective July 1, 2026) As revised, the Brown Act requires the City Council to reasonably assist community members providing or receiving translation and interpretation services from third parties at City Council meetings. These requirements do not apply to Council Committees or BCCs. While SB 707 requires some jurisdictions to translate their agendas, agenda translation is not required in Palo Alto at this time. Item 12 Item 12 Staff Report        Item 12: Staff Report Pg. 7  Packet Pg. 409 of 489  The City must make available to the public a physical posting space where members of the public may post their own translations of the City Council’s agendas. The City will provide notice that these translations are provided by third parties, and that the City cannot verify the content or accuracy of publicly provided agenda translations. Staff recommends authorizing the City Clerk to designate an appropriate posting board for this purpose. Staff currently recommends making the King Plaza posting board available for translated agendas and will post instructions and guidelines for how the public may utilize the space. Arrange a space for interpreters at the meeting location, upon written request to the City Clerk at least 24 hours before the meeting, Provide public commenters using interpretation extra time. Staff recommends providing twice as much public comment time for individuals using interpreters, or an amount of time determined by the presiding officer, Allow the public to use their own devices to access translation or interpretation services, and Loan City devices to the public to access translation or interpretation services upon request. Requests for City devices must be made in writing to the City Clerk at least 24 hours before the meeting. Information on borrowing City devices may be found on the City Clerk’s Translation Services webpage9. Outreach to Underrepresented Groups (effective July 1, 2026) 10” SB 707 provides examples of such groups, including media organizations, civil rights groups, and neighborhood organizations, including those that serve non-English-speaking communities. Publishes City Council agenda and agenda packet 11 days before meeting, rather than the minimum required 72 hours for regular meetings and 24 hours for special meetings, 9 City of Palo Alto Translation Services: https://www.paloalto.gov/Departments/City-Clerk/City-Meeting- Groups/Translation-Services 10 California Gov. Code Section 54953.4: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=54953.4. Item 12 Item 12 Staff Report        Item 12: Staff Report Pg. 8  Packet Pg. 410 of 489  Provides physical agenda packets for public review at Mitchell Park and Rinconada libraries, in addition to posting agendas in King’s Plaza (accessible 24/7) and in Council Chambers, Displays prominent link on city homepage to webpage with meeting schedule and agenda materials, Distributes a weekly newsletter of published agendas and meetings sent to over 1,500 people and prominently displays newsletter sign-up link on agenda website, Maintains a City website explaining the format of public meetings and how the public may participate, Publishes all City Council and Council Committee agendas, rather than only special meetings, in Palo Alto Weekly and Daily Post, Enables automatic translation of the City website into Spanish or simplified Chinese, Enables automatic translation of HTML agendas for all meeting bodies into over 200 languages, Offers free access to Wordly, a real-time audio and text translation service supporting over 50 languages, upon written request to the City Clerk at least 24 hours before the meeting. The public may use own device or borrow a City device to receive verbal and/or written interpretation. Instructions for requesting and using Wordly service are available on the City Clerk’s website, and Livestreams public meetings on YouTube and broadcasts on local cable television. Given the priorities of SB 707, staff recommends continuing the above efforts, taking the following additional actions, and continually updating and improving practices based on effectiveness: Share information about agenda notification newsletters with community groups and organizations such as neighborhood associations, non-English news media, service organizations, Post informational resources in the King’s Plaza and Council Chambers posting board and other public-facing City facilities with QR codes linking to the Agendas webpage, newsletter sign-up page, meeting participation guide, and translation services webpage, and Translate the Meeting Participation Guide13 into the two commonly spoken non-English languages as reported by the American Community Survey. These efforts are consistent with the City’s broader goals of transparency, accessibility, and inclusive civic engagement. 13 City of Palo Alto Meeting Participation Guide: https://www.paloalto.gov/files/assets/public/v/1/city-clerk/city- charterprocedures/2025-meeting-participation-guide.pdf Item 12 Item 12 Staff Report        Item 12: Staff Report Pg. 9  Packet Pg. 411 of 489  FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: Item 12 Item 12 Staff Report        Item 12: Staff Report Pg. 10  Packet Pg. 412 of 489  Policy: Disruption of Two-Way Remote Public Access Service 1. Purpose This policy establishes procedures for responding to a disruption in the telephonic or internet services that provide two-way remote public access to meetings of the City Council of the City of Palo Alto, as required by the Brown Act (Gov. Code § 54953.4). If state law is subsequently amended, the amended terms of state law will apply. 2. Definitions For purposes of this policy: “Disruption” means any failure, outage, or other interruption that prevents members of the public from attending or observing the meeting via a two-way telephonic service or two-way audiovisual platform. “Remote access services” means the two-way telephonic service and/or two-way audiovisual platform used to provide real-time remote public attendance and participation in meetings. Services that allow remote observation but not participation of meetings, such as a television broadcast or livestream, are not included. 3. Applicability This policy applies to all open and public meetings of the City Council of the City of Palo Alto at which remote public participation is offered or required under the Brown Act. 4. Procedures in the Event of a Service Disruption 4.1. Response to Service Disruption If the Presiding Officer or Clerk becomes aware of a disruption to the agency’s remote access services that prevents members of the public from attending or observing the meeting remotely: 1. The Presiding Officer or Clerk shall immediately announce the disruption to the public. 2. The Presiding Officer may then call for a recess of the open session or convene the legislative body in an agendized closed session. The Presiding Officer will make the following, or a substantially similar, announcement: “The City is experiencing a disruption of its remote access service that prevents remote public participation. In accordance with the Brown Act, the City Council will recess the meeting for at least one hour or until services are restored, whichever comes sooner. If service is not restored after one hour, the City Council may either vote that the public interest in continuing the public meeting outweighs the public interest in remote access and reconvene or adjourn the meeting.” 3. Staff shall begin efforts to diagnose and restore the disrupted service. 4. The meeting shall remain in recess for at least one hour or until service is restored, whichever is sooner. The recess period may be extended if restoration efforts are ongoing. 4.2. Efforts to Restore Service The agency shall make good faith efforts to restore remote access services, which may include: Troubleshooting platform or teleconferencing software Resetting or replacing audiovisual equipment Attempting alternative connection methods Item 12 Attachment A - Two-Way Remote Public Access Disruption Policy        Item 12: Staff Report Pg. 11  Packet Pg. 413 of 489  Contacting necessary support staff or service providers Switching to back-up equipment or platforms, if available 5. Reconvening the Open Session 5.1. Timing The open session may be reconvened after at least one hour has elapsed from the time of disruption or as soon as service is restored, whichever occurs earlier. 5.2. If Service Is Restored If the remote access service is restored before or at the time the meeting reconvenes, the meeting shall continue as normal. 5.3. If Service Is Not Restored If service has not been restored after one hour, the City Council of the City of Palo Alto may reconvene and: 1. Adjourn the meeting; or 2. Continue the meeting in open session by adopting, by roll call vote, the following, or a substantially similar, finding: “The City of Palo Alto has made good faith efforts to restore remote access services in accordance with its adopted policy, and the public interest in continuing the meeting outweighs the public interest in remote public access.” Upon adoption of the finding, the legislative body may continue the open session. 6. Recordkeeping The Clerk shall enter a brief statement into the meeting minutes, including the following: The nature and time of the disruption That good faith efforts to restore service were made in accordance The time the meeting was reconvened (if applicable) Any finding adopted pursuant to Section 6.3 7. Review and Updates This policy may be amended by the City Council of the City of Palo Alto at a noticed public meeting in open session, not on the consent calendar. Item 12 Attachment A - Two-Way Remote Public Access Disruption Policy        Item 12: Staff Report Pg. 12  Packet Pg. 414 of 489  1 0 4 2 4 City Practices Already in Alignment with SB 707 This attachment describes SB 707 requirements that are satisfied by current City practices and by recent updates and do not need additional implementation. Alternative Teleconferencing (effective January 1, 2026) Before 2020, the Brown Act only permitted members of Brown Act bodies to attend meetings remotely if the member published their remote address on the agenda, allowed public access at their remote location, and posted the agenda at their remote location, among other requirements. This open location form of remote attendance is referred to as “standard teleconferencing.” SB 707 does not change this form of teleconferencing. During the Covid-19 state of emergency, the Brown Act permitted members to attend meetings remotely without opening their location to the public if they complied with another set of requirements. After the state of emergency ended, the legislature continued to experiment with narrow reasons (i.e. “just cause” or “emergency circumstances”) that a member could attend remotely without publishing the remote meeting location or making the location open to the public. This is referred to as “alternative teleconferencing” and was established by AB 2449 (2021-2022). Other rules apply to alternative teleconferencing, such as the requirement to participate by video throughout the meeting. SB 707 extends and revises the alternative teleconferencing provisions of AB 2449. Some notable changes include: Extends expiration date to 2030, Removes the procedural differences between attending remotely due to “just cause” or “emergency circumstances,” Expands “just cause” to include certain military service obligations, Modifies the annual limit on attendance by alternative teleconference based on the body’s frequency of regular meetings, and Requires meeting minutes to identify specific provision a member relies on to participate remotely. The City Council adopted the updated provisions as part of its most recent Procedures & Protocols Handbook update. Brown Act Distribution (effective January 1, 2026) SB 707 converts a previously optional authority into a mandate. Cities are now required to provide the Brown Act to elected and appointed members of legislative bodies, including City Council and BCCs. The City Clerk’s Office provides the Brown Act as part of the reference materials given to all new 1 February 9, 2026 City Council Action Minutes: https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=86544&dbid=0&repo=PaloAlto Item 12 Attachment B - City Practices Already in Alignment with SB 707        Item 12: Staff Report Pg. 13  Packet Pg. 415 of 489  1 0 4 2 4 commissioners during their orientation and will incorporate this mandate into new Councilmember onboarding practices. Remote Member Participation as an Accommodation (effective January 1, 2026) A member of any legislative body may now participate remotely as a reasonable accommodation for a disability. The member’s participation counts as in-person for quorum purposes. Members using this form of teleconference must: Disclose the presence of anyone over the age of 18 with them and their relationship to that person, and Use audio and visual technology, unless a physical condition related to their disability results in a need to participate only through audio. City Clerk staff will coordinate on an as-needed basis with members using this form of teleconference. Remote Public Attendance SB 707 requires certain legislative bodies to offer a remote public participation option. In Palo Alto, the City Council is the only legislative body required to provide a remote option. Existing City Clerk practice surpasses this requirement. Palo Alto currently uses Zoom to host meetings and take comments on agendized items at all City Council, Council Committees, and BCC meetings. The City also livestreams meetings to YouTube and broadcasts to local cable television as additional viewing options for the public. Website Requirements (effective July 1, 2026) SB 707 requires a city’s homepage to include a prominent link to a public meeting webpage. The webpage must include or link to: a general explanation of the public meeting process, an explanation of how to provide in-person or remote verbal or written public comment, a calendar of all public meetings with the times, dates, and locations, and a link to posted agendas. A link to the City’s Meeting Agendas and Minutes page3 is prominently displayed on Palo Alto’s homepage and complies with these requirements. In addition to the Agendas page, the City Clerk’s Office also maintains a Resources for Meeting Attendance4 webpage. This page includes information about City Council meeting structure, public comment procedures, FAQs, City Council and BCC meeting frequencies, and resources for remote attendance. The City Clerk’s Office’s online newsletter meets new requirements regarding electronic meeting agenda distribution. A city must now provide a system to electronically accept and fulfill requests for meeting agendas and display a sign-up link on the City Council’s homepage. The City Clerk’s Office sends a weekly 3 City of Palo Alto Meeting Agendas and Minutes: https://PaloAlto.gov/CouncilAgendas 4 City of Palo Alto Resources for Public Meetings: https://www.paloalto.gov/Departments/City-Clerk/City-Meeting- Groups/Resources-for-Meeting-Attendance Item 12 Attachment B - City Practices Already in Alignment with SB 707        Item 12: Staff Report Pg. 14  Packet Pg. 416 of 489  1 0 4 2 4 newsletter with information about City Council and Council Committee meetings and events, including direct links to all published agendas and notifications of amended or supplemental materials. The newsletter is currently distributed to over 1,500 individuals, and the public may sign up online via a prominent link on the Meeting Agendas and Minutes page. Item 12 Attachment B - City Practices Already in Alignment with SB 707        Item 12: Staff Report Pg. 15  Packet Pg. 417 of 489  City Council Staff Report Report Type: INFORMATION REPORTS Lead Department: Administrative Services Meeting Date: April 20, 2026 Report #:2602-6002 TITLE Monthly Investment Report - March 2026 (Unaudited) RECOMMENDATION This is an Information Report. No Council action is required. EXECUTIVE SUMMARY The City’s Investment Policy (Policy)1 and California Government Code Section 53607 requires that a report of transactions (investments, reinvestment, sold, and exchanged securities) be made available to the Council on a monthly basis. This reporting requirement is separate and distinct from the quarterly investment report submitted under California Government Code Section 53646 that includes portfolio composition, a detailed list of all securities, performance compared to the Policy, overall compliance with the Policy, and the City’s ability to meet expenditure requirements over the next six months. ATTACHMENTS Attachment A: Investment Portfolio Transaction Ledger – March 2026 APPROVED BY: Lauren Lai, Administrative Services Director 1 Investment Policy Fiscal Year 2025-2026 (Adopted February 2026); Item A Item A Staff Report        Item A: Staff Report Pg. 1  Packet Pg. 418 of 489  Buy Call Redemption Maturity CUSIP Security Description Security Type Transaction Type Settlement Date Quantity Price Acq/Disp Yield Amount Purchased/Sold Interest Total Amount 91282CQB0 UNITED STATES TREASURY 3.375 02/29/2028 US GOV Buy 03/20/2026 10,000,000.00 99.227 3.790 -9,922,656.25 18,342.39 -9,940,998.64 91282CGH8 UNITED STATES TREASURY 3.5 01/31/2028 US GOV Buy 03/13/2026 5,000,000.00 99.547 3.749 -4,977,343.75 19,820.44 -4,997,164.19 912797SM0 UNITED STATES TREASURY 04/23/2026 T-BILL Buy 03/31/2026 5,000,000.00 99.767 3.704 -4,988,358.17 0.00 -4,988,358.17 912797QN0 UNITED STATES TREASURY 05/14/2026 T-BILL Buy 03/31/2026 5,000,000.00 99.557 3.693 -4,977,838.06 0.00 -4,977,838.06 91159HJT8 US BANCORP 5.046 02/12/2031 CORP Buy 03/25/2026 2,500,000.00 101.047 4.746 -2,526,175.00 15,067.92 -2,541,242.92 87269AAA8 TMUST 261 A 4.25 10/21/2030 ABS Buy 03/20/2026 1,870,000.00 99.979 4.255 -1,869,603.19 0.00 -1,869,603.19 79466LAR5 SALESFORCE INC 4.65 03/15/2029 CORP Buy 03/20/2026 1,150,000.00 100.007 4.648 -1,150,080.50 1,039.79 -1,151,120.29 47787DAD3 JDOT 2026 A3 3.87 08/15/2030 ABS Buy 03/18/2026 1,755,000.00 99.982 4.489 -1,754,689.01 0.00 -1,754,689.01 3137FKZZ2 FHMS K-088 A2 3.69 01/25/2029 FHLMC Buy 03/31/2026 4,855,000.00 98.434 4.239 -4,778,950.98 14,929.13 -4,793,880.11 24422EYE3 JOHN DEERE CAPITAL CORP 4.55 06/05/2030 CORP Buy 03/20/2026 2,500,000.00 100.629 4.383 -2,515,725.00 33,177.08 -2,548,902.08 023135DD5 AMAZON.COM INC 4.25 03/13/2031 CORP Buy 03/13/2026 1,535,000.00 99.733 4.310 -1,530,901.55 0.00 -1,530,901.55 023135DD5 AMAZON.COM INC 4.25 03/13/2031 CORP Buy 03/27/2026 1,215,000.00 98.863 4.508 -1,201,185.45 2,008.13 -1,203,193.58 ---------Buy 03/23/2026 42,380,000.00 ---4.020 -42,193,506.91 104,384.88 -42,297,891.79 CUSIP Security Description Security Type Transaction Type Settlement Date Quantity Price Acq/Disp Yield Amount Purchased/Sold Interest Total Amount 6500357D4 NEW YORK ST URBAN DEV CORP REV 3.07 03/15/2026 MUNI Call Redemption 03/15/2026 -700,000.00 100.000 2.100 700,000.00 0.00 700,000.00 396916AC2 GreenWay Bank 4.35 04/03/2028 CD Call Redemption 03/03/2026 -250,000.00 100.000 4.350 250,000.00 0.00 250,000.00 3133ETAF4 FEDERAL FARM CREDIT BANKS FUNDING CORP 4.9 03/19/2031 AGCY BOND Call Redemption 03/19/2026 -1,985,000.00 100.000 4.919 1,985,000.00 0.00 1,985,000.00 3133ER5R8 FEDERAL FARM CREDIT BANKS FUNDING CORP 5.25 03/03/2034 AGCY BOND Call Redemption 03/03/2026 -1,500,000.00 100.000 5.250 1,500,000.00 0.00 1,500,000.00 ---------Call Redemption 03/12/2026 -4,435,000.00 100.000 4.554 4,435,000.00 0.00 4,435,000.00 CUSIP Security Description Security Type Transaction Type Settlement Date Quantity Price Acq/Disp Yield Amount Purchased/Sold Interest Total Amount 91282CBQ3 UNITED STATES TREASURY 0.5 02/28/2026 US GOV Maturity 02/28/2026 0.00 100.000 0.831 0.00 0.00 1,500,000.00 912797SZ1 UNITED STATES TREASURY 03/17/2026 T-BILL Maturity 03/17/2026 -10,000,000.00 100.000 3.672 10,000,000.00 0.00 10,000,000.00 59001PAP4 Meritrust Federal Credit Union 0.55 03/10/2026 CD Maturity 03/10/2026 -249,000.00 100.000 1.932 249,000.00 0.00 249,000.00 Palo Alto Monthly Transactions 03/01/2026 - 03/31/2026 1 ATTACHMENT A Item AAttachment A - InvestmentPortfolio TransactionLedger - March 2026       Item A: Staff Report Pg. 2  Packet Pg. 419 of 489  Summary CUSIP Security Description Security Type Transaction Type Settlement Date Quantity Price Acq/Disp Yield Amount Purchased/Sold Interest Total Amount 478160BY9 JOHNSON & JOHNSON 2.45 03/01/2026 CORP Maturity 03/01/2026 -3,000,000.00 100.000 0.823 3,000,000.00 0.00 3,000,000.00 45950VPU4 INTERNATIONAL FINANCE CORP 0.75 03/23/2026 SUPRANATIONAL Maturity 03/23/2026 -3,500,000.00 100.000 0.839 3,500,000.00 0.00 3,500,000.00 45950VPT7 INTERNATIONAL FINANCE CORP 2.5 03/15/2026 SUPRANATIONAL Maturity 03/15/2026 -2,000,000.00 100.000 0.820 2,000,000.00 0.00 2,000,000.00 31422XDX7 FEDERAL AGRICULTURAL MORTGAGE CORP 0.83 03/27/2026 AGCY BOND Maturity 03/27/2026 -4,755,000.00 100.000 0.878 4,755,000.00 0.00 4,755,000.00 3130ALF33 FEDERAL HOME LOAN BANKS 0.75 03/16/2026 AGCY BOND Maturity 03/16/2026 -1,925,000.00 100.000 0.113 1,925,000.00 0.00 1,925,000.00 20368QAD8 Community Choice Credit Union 4.0 03/30/2026 CD Maturity 03/30/2026 -249,000.00 100.000 4.000 249,000.00 0.00 249,000.00 ---------Maturity 03/18/2026 -25,678,000.00 100.000 1.933 25,678,000.00 0.00 27,178,000.00 CUSIP Security Description Security Type Transaction Type Settlement Date Quantity Price Acq/Disp Yield Amount Purchased/Sold Interest Total Amount ------------03/21/2026 12,267,000.00 ---3.311 -12,080,506.91 104,384.88 -10,684,891.79 Palo Alto Monthly Transactions 03/01/2026 - 03/31/2026 2 ATTACHMENT A Item AAttachment A - InvestmentPortfolio TransactionLedger - March 2026       Item A: Staff Report Pg. 3  Packet Pg. 420 of 489  Item No. 6. Page 1 of 2 City Council Supplemental Report From: Jonathan Lait, Planning and Development Services Director Meeting Date: April 20, 2026 Item Number: 6 Report #:2604-6260 TITLE Adopt a Resolution Authorizing the Director of Planning and Development Services to Make Minor Modifications to the 2023-2031 Housing Element Site Inventory. CEQA Status: The City Council adopted a Revised Addendum to the Comprehensive Plan Final Environmental Impact Report on December 18, 2023, that, in conjunction with the Comprehensive Plan Final EIR, fully analyzes the impacts of the 6th Cycle Housing Element, including minor modifications to the site inventory. RECOMMENDATION Staff recommends that the City Council adopt a resolution to authorize the Director of Planning and Development Services to make modifications to the 2023-2031 Housing Element site inventory that are consistent with the adopted Housing Element. BACKGROUND This transmittal provides additional information on the objective criteria that will be used to identify new Housing Element opportunity sites to replace Regional Housing Needs Allocation (RHNA) capacity. If the City Council adopts the resolution, the Director of Planning and Development Services will apply these criteria to evaluate site suitability. Approving this process for minor modifications to the 2023–2031 Housing Element Site Inventory will help the City maintain compliance with state law and the Housing Element’s Adequate Sites Program. Evaluation Criteria Staff will evaluate candidate Housing Element opportunity sites using the same objective criteria used to identify the City’s existing opportunity sites. The California Department of Housing and Community Development (HCD) accepted these criteria as part of the City’s approach to meeting RHNA requirements, and they are described in the Housing Element (pp. 3-25 to 3-33). Examples include: Improvement to land value ratio Vacant buildings Item 6 Item 6 Supplemental Report        Item 6: Staff Report Pg. 1  Packet Pg. 421 of 489  Item No. 6. Page 2 of 2 Structure age Developer interest Existing use/current zoning Staff will also consider additional criteria in response to changing circumstances, including implementation of SB 79, and re-evaluate previously studied sites. These tools will be used to screen sites and assess redevelopment potential. Selection Criteria Prior to making any determination of whether a site will be added to the Housing Element site inventory, the Director will review candidate sites based on the following selection criteria: Exclusions: o R1 zones o Sites immediately adjacent to R1 o Environmentally sensitive areas, such as the foothills or Baylands Prioritized locations: o Sites within ½ mile of Caltrain stations o Locations within commercial or mixed-use corridors, particularly in locations with transit or bike facilities o Locations within area plans or planning focus areas The Director will add sites to the inventory as necessary to meet state requirements for RHNA at each income level and to maintain an adequate buffer. Reporting The Director will submit a report to the City Council when changes are made to the Housing Element site inventory. In addition, changes will be reported to HCD annually as part of the state-mandated reporting requirements. APPROVED BY: Jonathan Lait, Planning and Development Services Director Item 6 Item 6 Supplemental Report        Item 6: Staff Report Pg. 2  Packet Pg. 422 of 489  Item No. 10. Page 1 of 1 City Council Supplemental Report From: Jonathan Lait, Planning and Development Services Director Meeting Date: April 20, 2026 Item Number: 10 Report #:2604-6256 TITLE 4075 El Camino Way [23PLN-00202]: Recommendation to Decline Adoption on Second Reading of an Ordinance Adopting an Amendment to a Planned Community Ordinance (PC-5116) to Allow for Modifications to an Existing 121-Unit Assisted Living and Memory Care Facility. First Reading Adoption was on March 16, 2026. CEQA Status: Exempt from the Provisions of the California Environmental Quality Act (CEQA) in Accordance with CEQA Guidelines Section 15301 (Modifications to Existing Facilities). RECOMMENDATION Staff recommends that the City Council: 1. Decline to adopt the second reading ordinance allowing the application to be withdrawn as requested by the applicant. BACKGROUND The published report for the subject item incorrectly stated three votes were required to pull the second reading ordinance from the consent calendar; four votes are required. This provision is set forth in the City Council Procedures and Protocols Handbook Section 3.8 (f). ATTACHMENTS None APPROVED BY: Jonathan Lait, Planning and Development Services Director Item 10 Item 10 Supplemental Report        Item 10: Staff Report Pg. 1  Packet Pg. 423 of 489  City Council Staff Report From: City Clerk Report Type: CONSENT CALENDAR Lead Department: Public Works Meeting Date: April 20, 2026 Report #:2604-6268 TITLE Amend the FY 2026 Budget Appropriation for the Capital Improvement Fund to Establish the Embarcadero Road Improvement Project, Phase 1, and Authorize the City Manager or Their Designee to Award a Construction Contract with a Qualified Contractor for the Embarcadero Road Improvement Project, Phase 1; CEQA Status – Exempt under CEQA Guidelines Section 15301(c) This report will be published as an at-places memo on Monday, April 20, 2026. Item AA1 Item AA1 Staff Report        Item AA1: Staff Report Pg. 1  Packet Pg. 424 of 489  City Council Staff Report From: City Manager Report Type: INFORMATION REPORTS Lead Department: Community Services Meeting Date: April 20, 2026 Report #:2604-6218 TITLE Informational Update on Stanford Palo Alto Community Playing Fields (Mayfield) PFAS Testing Results RECOMMENDATION This is an informational report and no City Council action is required. BACKGROUND On June 9, 20251, the City Council approved Construction Contract No. C25193640 with FieldTurf USA, Inc. in the amount of $3,064,185, along with a contingency of $306,419, for the Stanford Palo Alto Community Playing Fields Turf Replacement Project (PG-26000). At that time, staff issued a supplemental memorandum addressing the question of whether the selected synthetic turf system would be free of per- and polyfluoroalkyl substances (PFAS) and whether testing would be conducted to confirm this. The memorandum stated that “…staff have confirmed that FieldTurf manufactures synthetic turf products without intentionally- added PFAS and this is the product that will be installed at Stanford Palo Alto Playing Fields. FieldTurf will test the product after installation to verify no intentionally-added PFAS.” Staff have since consulted with the California Department of Toxic Substances Control (DTSC) and coordinated with an independent testing laboratory using a National Environmental Laboratory Accreditation Program (NELAP)-accredited laboratory to conduct testing. The specific testing methodology is known as Total Organic Fluorine (TOF) testing, and measures the total amount of organically bound fluorine in a material by subtracting inorganic fluorine from total fluorine. This includes fluorine from known and unknown PFAS, precursor compounds, and other organofluorine substances. TOF is widely recognized as a conservative 1 City Council, June 9, 2025; Agenda Item #9, SR #2506-4816, Item AA2 Item AA2 Staff Report        Item AA2: Staff Report Pg. 1  Packet Pg. 425 of 489  and screening approach for evaluating the potential presence of fluorinated compounds associated with PFAS, particularly in complex materials such as synthetic turf. ANALYSIS Item AA2 Item AA2 Staff Report        Item AA2: Staff Report Pg. 2  Packet Pg. 426 of 489  FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: Item AA2 Item AA2 Staff Report        Item AA2: Staff Report Pg. 3  Packet Pg. 427 of 489  Field Turf_Mayfield_m022326m One Beacon Street , 17th Floor, Boston, MA 02108 | 617-395-5000 | www.gradientcorp.com Memorandum To: Sara Marinelli, Josh Robinson (FieldTurf) Date: February 23, 2026 From: Catalina Restrepo, Michael Peterson, and Kim Reid (Gradient) Subject: Mayfield Soccer Complex Total Organic Fluorine (TOF) Results Executive Summary This memorandum summarizes the validated laboratory testing results of FieldTurf's product intended for installation at the Mayfield Soccer Complex in Palo Alto, California. This testing was conducted to verify FieldTurf's claim that their synthetic turf product "FTVTP2-RE3-39-PFF-FS-STND, does not contain any intentionally added per- and poly-fluoroalkyl substances (PFAS) in its formulation or manufacturing process" (see Appendix A). To determine if the product contains intentionally added per- and polyfluoroalkyl substances (PFAS), laboratory testing was conducted at Pace Labs in Minnesota and Massachusetts. All laboratories involved in this testing are accredited by the National Environmental Laboratory Accreditation Program (NELAP). Laboratory testing for PFAS compounds in synthetic turf products is difficult due to the complex matrix of the products as well as the wide variety of PFAS compounds that could potentially be present in construction materials. In addition, there are not validated commercially available methods to test for the types of fluoropolymers that historically may have been used in some synthetic turf fibers. Due to these issues, testing for total organic fluorine (TOF) was recommended for this project, as California legislation has suggested that the presence of organic fluorine is an indicator of possible intentionally added PFAS compounds in products. TOF testing has significant limitations in that it can overestimate the presence of PFAS compounds, but it was still deemed the best available method for the purposes of this project. The TOF results for the two Mayfield Soccer Complex FieldTurf product samples were 8.7 and 11 parts per million (ppm), which are both below regulatory guidelines that have been promulgated for consumer products1 in California and other states (TOF content limit of 100 or 50 ppm; see, e.g., California bill AB 347 [California, State Assembly, 2024]). Sample Collection and Analysis Samples of the FieldTurf product intended for installation at the Mayfield Soccer Complex were collected on 12/18/2025 by FieldTurf staff in accordance with the Sampling and Analysis Plan (SAP), which was developed by Gradient in collaboration with FieldTurf and Pace Labs. See Table 1 for a summary of the sample information. Although there are no validated analytical methods specifically designed to test synthetic field turf materials, Gradient designed the SAP to include testing of the material in solid form. 1 These regulatory limits are not specifically relevant to synthetic turf, but provide useful guidelines for comparison. In general, the limits are intended to determine whether or not a product might contain intentionally added PFAS compounds. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 4  Packet Pg. 428 of 489  2 Field Turf_Mayfield_m022326m Determining TOF is a way of determining total PFAS levels in a sample; however, there currently are no validated methods available for testing for TOF in solid media or artificial field turf. Therefore, the samples first underwent cryomilling, followed by total fluorine analysis by combustion ion chromatography (CIC) and inorganic fluoride analysis by Method 121,4500F-BC. Then, we derived the TOF concentration in each sample by subtracting the inorganic fluoride results from the total fluorine results. Table 1 FieldTurf Sample Information Sample ID Product Name Product Description Date Collected Laboratory Report # Mayfield-1 Carpet retain Synthetic turf 12/18/2025 10760348 Mayfield-2 (duplicate) Analytical Result Summary Pace Labs reported the analysis results in laboratory report number 10760348 (see Appendix B). Duplicate samples were submitted to the laboratory for analysis according to the laboratory's corresponding standard operating procedure for each method. Both samples Mayfield-1 and Mayfield-2 had detected levels of total fluorine (8.7 and 11 mg/kg, respectively) and non-detected levels of inorganic fluoride. Therefore, the calculated TOF is 8.7 and 11 mg/kg for samples Mayfield-1 and Mayfield-2, respectively. Table 2, below, summarizes the results of the analyses. Data Validation All the reported analytical data were validated according to the requirements listed in US EPA "Guidance on Environmental Data Verification and Data Validation" (US EPA, 2002) and the professional judgment of the reviewers. The laboratory provided a Level 2 analysis report; thus, raw data were not reviewed during the validation process. Table 2, below, presents a summary of the validated results for the Mayfield Soccer Complex FieldTurf sample analyses. In general, there was good agreement between the primary and duplicate sample analyses performed across both methods, demonstrating that acceptable precision was achieved. Overall, no technical issues affecting the completeness, sensitivity, accuracy, or precision of the sample data were identified during data validation. Appendix C contains the associated data validation report. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 5  Packet Pg. 429 of 489  3 Field Turf_Mayfield_m022326m Table 2 Summary of Validated Detected Results for Organic Fluorine Analyses of the Mayfield Soccer Complex FieldTurf Samples Sample ID TFa (mg/kg) IFb (mg/kg) TOFc (mg/kg) Result DV Qualifier RL Result DV Qualifierd RL Mayfield-1 8.7 – 4 N/A – Result ND U 10 8.7 Mayfield-2 11 – 4 N/A – Result ND U 10 11 Notes: CIC = Combustion Ion Chromatography; DV = Data Validation; IF = Inorganic Fluoride; N/A = Not Applicable; ND = Not Detected; RL = Reporting Limit; TF = Total Fluorine; TOF = Total Organic Fluorine. DV Qualifier: U = Not-detected. (a) Solid media analysis. Extraction method: cryomilling. Analysis method: TF by CIC. (b) Solid media analysis. Extraction method: cryomilling. Analysis method: Method 121,4500F-BC. (c) Calculated as TF Concentration – IF Concentration. (d) Appendix C contains a full list of the DV qualifiers, including for detected and non-detected values. Conclusion PFAS are widespread in the environment and in commercial products. Historically, PFAS have been used as a processing aid during the production of synthetic turf products, which has led to concerns regarding potential exposures. In addition, some states have banned the sale of synthetic turf that contains PFAS. This study provides investigation of the potential occurrence of intentionally added PFAS in product materials. Because there is currently no analytical method for measuring TOF in solid media, we derived the TOF content of the samples by subtracting the concentration of inorganic fluoride from the concentration of total fluorine. The Mayfield-1 sample and its duplicate sample (Mayfield-2) had detectable levels of total fluorine (8.7 and 11 mg/kg, respectively), and inorganic fluoride levels were non-detected in both samples. Therefore, the calculated TOF concentrations are 8.7 and 11 mg/kg (equivalent to 8.7 and 11 ppm) for samples Mayfield-1 and Mayfield-2, respectively. These results are below all current regulatory standards for TOF. For example, California Proposition 65 settlements for PFAS generally specify that TOF content in textiles and other products should not exceed 100 ppm (0.01%) (see, e.g., BVCPS [2025]). California bill AB 347 limits TOF in textiles and juvenile products to less than 100 ppm (California, State Assembly, 2024). Vermont restricts TOF to less than 100 ppm in textiles, and will lower this value to 50 ppm in 2027 (Vermont, General Assembly, 2024). Overall, these results are not indicative of the presence of intentionally added PFAS compounds in the tested FieldTurf product and support FieldTurf's claims (Appendix A). Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 6  Packet Pg. 430 of 489  4 Field Turf_Mayfield_m022326m References Bureau Veritas Consumer Products Services, Inc. (BVCPS). 2025. "California Proposition 65 Settlements." 25B-028. 1p., March. California, State Assembly. 2024. "Assembly Bill No. 347: An act to amend Section 108945 of, to add Chapter 3 (commencing with Section 108075) to Part 3 of Division 104 of, to repeal the heading of Chapter 3 of Part 3 of Division 104 of, and to repeal Article 7 (commencing with Section 108087) of Chapter 3 of Part 3 of Division 104 of, the Health and Safety Code, relating to consumer protection." AB 347. 6p., September 29. US EPA. 2002. "Guidance on Environmental Data Verification and Data Validation (Final)." Office of Environmental Information. EPA/240/R-02/004, EPA QA/G-8, 95p., November. Vermont, General Assembly. 2024. "An act relating to regulating consumer products containing perfluoroalkyl and polyfluoroalkyl substances or other chemicals." No. 131. 29p., May 30. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 7  Packet Pg. 431 of 489  Field Turf_Mayfield_m022326m Appendix A FieldTurf Confirmation Letter Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 8  Packet Pg. 432 of 489  FieldTurf Tel (800) 724-2969 www.fieldturf.com December 2, 2025 Ben Heistein Assistant Director - Open Space, Parks, and Golf Community Services Department City of Palo Alto Mayfield Soccer Complex Subject: Confirmation of No Intentionally added PFAS Mr. Heistein, We are writing to confirm that our turf product, FTVTP2-RE3-39-PFF-FS-STND, does not contain any intentionally added per- and poly-fluoroalkyl substances (PFAS) in its formulation or manufacturing process. At FieldTurf, we are committed to transparency, environmental stewardship, and the safety of the communities we serve. We remain vigilant in our materials selection and testing protocols to ensure our products meet the highest standards for health and environmental responsibility. If you have any questions or would like to review the supporting documentation, please do not hesitate to contact us. Sincerely, Darren Gill Executive Vice-President dgill@fieldturf.com (514) 375-2584 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 9  Packet Pg. 433 of 489  Field Turf_Mayfield_m022326m Appendix B Laboratory Report Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 10  Packet Pg. 434 of 489  1(612)607-6351 The test results provided in this final report were generated by each of the following laboratories within the Pace Network: Enclosed are the analytical results for sample(s) received by the laboratory on December 22, 2025. The results relate only to the samples included in this report. Results reported herein conform to the applicable TNI/NELAC Standards and the laboratory's Quality Manual, where applicable, unless otherwise noted in the body of the report. Dear Catalina Restrepo: RE:Project:223101 Field Turf (9) Mayfield Pace Project No.:10760348 Catalina Restrepo Gradient Corporation 1 Beacon Street, 17th Floor Boston, MA 02108 If you have any questions concerning this report, please feel free to contact me. Sincerely, Enclosures Michael Peterson, Gradiant Corporation Kim Reid, Gradient Corporation cc: January 14, 2026 Carolynne Trout carolynne.trout@pacelabs.com Project Manager 1700 Elm Street Pace Analytical Services, LLC Minneapolis, MN 55414 (612)607-1700 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC. 1 of 6 10760348 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 11  Packet Pg. 435 of 489  Table of Contents -2- Section 1: Sample Summary .............................................................................................................3 Section 2: Chain of Custody ..............................................................................................................4 2.1: Chain of Custody ....................................................................................................................4 Sections:1 2 2 of 6 10760348 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 12  Packet Pg. 436 of 489  Lab ID Sample ID Matrix Date Collected Date Received 10760348001 Mayfield-1 Solid 12/18/25 02:02 12/22/25 10:15 10760348002 Mayfield-1 Solid 12/18/25 02:10 12/22/25 10:15 10760348003 Mayfield-2 Solid 12/18/25 02:18 12/22/25 10:15 10760348004 Mayfield-2 Solid 12/18/25 02:25 12/22/25 10:15 SAMPLE SUMMARY 1700 Elm Street Pace Analytical Services, LLC Minneapolis, MN 55414 (612)607-1700 Project:223101 Field Turf (9) Mayfield Pace Project No.:10760348 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, LLC.Date: 01/14/2026 04:30 PM 1 3 of 6 10760348 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 13  Packet Pg. 437 of 489  2 2. 1 4 of 6 10760348 Item AA2Attachment A - MayfieldSoccer Complex TotalOrganic Fluorine (TOF)Results       Item AA2: Staff Report Pg. 14  Packet Pg. 438 of 489  12/23/25 2 2. 1 5 of 6 10760348 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 15  Packet Pg. 439 of 489  2 2. 1 6 of 6 10760348 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 16  Packet Pg. 440 of 489  39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Pace Analytical Services , LLC - East Longmeadow, Ma January 9, 2026 Carolynne Trout Pace Analytical Laboratory - MN 1700 Elm Street Minneapolis, MN 55414 Project Location: 223101 Field Turf (task9) Client Job Number: Project Number: 10760348 Laboratory Work Order Number: 26A0197 Enclosed are results of analyses for samples as received by the laboratory on January 8, 2026. If you have any questions concerning this report, please feel free to contact me. Sincerely, Rebecca Faust Project Manager Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 17  Packet Pg. 441 of 489  Table of Contents Sample Summary 3 Case Narrative 4 Sample Results 5 26A0197-01 5 26A0197-02 6 Sample Preparation Information 7 QC Data 8 Fluorine by Combustion Ion Chromatography (CIC) 8 B420497 8 Flag/Qualifier Summary 9 Certifications 10 Chain of Custody/Sample Receipt 11 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 18  Packet Pg. 442 of 489  39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Pace Analytical Services , LLC - East Longmeadow, Ma ANALYTICAL SUMMARY 1/9/2026 Pace Analytical Laboratory - MN 1700 Elm Street Minneapolis, MN 55414 ATTN: Carolynne Trout 10760348 26A0197 The results of analyses performed on the following samples submitted to Pace Analytical Services , LLC - East Longmeadow, Ma, are found in this report. PROJECT LOCATION: PURCHASE ORDER NUMBER: PROJECT NUMBER: REPORT DATE: WORK ORDER NUMBER: FIELD SAMPLE #LAB ID:MATRIX TESTSAMPLE DESCRIPTION SUB LAB 223101 Field Turf (task9) 10760348 Mayfield-1 26A0197-01 Product/Solid Total Fluorine by CIC Mayfield-2 26A0197-02 Product/Solid Total Fluorine by CIC [TOC_1]Sample Summary[TOC] Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 19  Packet Pg. 443 of 489  39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Pace Analytical Services , LLC - East Longmeadow, Ma CASE NARRATIVE SUMMARY All reported results are within defined laboratory quality control objectives unless listed below or otherwise qualified in this report. [TOC_1]Case Narrative[TOC] The results of analyses reported only relate to samples submitted to Pace Analytical Services , LLC - East Longmeadow, Ma, for testing. I certify that the analyses listed above, unless specifically listed as subcontracted, if any, were performed under my direction according to the approved methodologies listed in this document, and that based upon my inquiry of those individuals immediately responsible for obtaining the information, the material contained in this report is, to the best of my knowledge and belief, accurate and complete. Lisa A. Worthington Technical Representative Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 20  Packet Pg. 444 of 489  39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Pace Analytical Services , LLC - East Longmeadow, Ma Date Received: 1/8/2026 Work Order: 26A0197Sample Description:Project Location: 223101 Field Turf (task9) Sample ID: 26A0197-01 Field Sample #: Mayfield-1 Sample Matrix: Product/Solid Sampled: 12/18/2025 02:02 [TOC_2]26A0197-01[TOC] AnalystAnalyzedDilutionFlag/QualRLResultsAnalyte Date/Time Units Date PreparedMethod Fluorine by Combustion Ion Chromatography (CIC) 8.7 4.0 1/8/26 20:20 MMHmg/Kg 1/8/26Total Fluorine by CIC1Total Fluorine (TF) [TOC_1]Sample Results[TOC] Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 21  Packet Pg. 445 of 489  39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Pace Analytical Services , LLC - East Longmeadow, Ma Date Received: 1/8/2026 Work Order: 26A0197Sample Description:Project Location: 223101 Field Turf (task9) Sample ID: 26A0197-02 Field Sample #: Mayfield-2 Sample Matrix: Product/Solid Sampled: 12/18/2025 02:18 [TOC_2]26A0197-02[TOC] AnalystAnalyzedDilutionFlag/QualRLResultsAnalyte Date/Time Units Date PreparedMethod Fluorine by Combustion Ion Chromatography (CIC) 11 4.0 1/8/26 20:41 MMHmg/Kg 1/8/26Total Fluorine by CIC1Total Fluorine (TF) Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 22  Packet Pg. 446 of 489  39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Pace Analytical Services , LLC - East Longmeadow, Ma Sample Extraction Data Prep Method:EPA 1621 (TF) Analytical Method:Total Fluorine by CIC Lab Number [Field ID]Batch DateInitial [mg]Final [Boat] B420497 01/08/2650.6 1.0026A0197-01 [Mayfield-1] B420497 01/08/2650.5 1.0026A0197-02 [Mayfield-2] [TOC_1]Sample Preparation Information[TOC] Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 23  Packet Pg. 447 of 489  39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Pace Analytical Services , LLC - East Longmeadow, Ma Result Limit Reporting Units Level Spike Result Source %REC %REC Limits RPD RPD Limit Notes Analyte Fluorine by Combustion Ion Chromatography (CIC) - Quality Control QUALITY CONTROL [TOC_2]Fluorine by Combustion Ion Chromatography (CIC)[TOC] Batch B420497 - EPA 1621 (TF) [TOC_3]B420497[TOC] Blank (B420497-BLK1) Prepared & Analyzed: 01/08/26 Total Fluorine (TF)mg/Kg4.0ND LCS (B420497-BS1) Prepared & Analyzed: 01/08/26 Total Fluorine (TF)mg/Kg3.9 36.84 70-13093.134.3 LCS (B420497-BS2) Prepared & Analyzed: 01/08/26 Total Fluorine (TF)mg/Kg3.9 36.55 70-13010337.7 LCS (B420497-BS3) Prepared & Analyzed: 01/08/26 Total Fluorine (TF)mg/Kg3.9 36.62 70-13010337.6 LCS Dup (B420497-BSD1) Prepared & Analyzed: 01/08/26 Total Fluorine (TF)mg/Kg3.9 36.13 70-130101 6.3536.5 [TOC_1]QC Data[TOC] Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 24  Packet Pg. 448 of 489  39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Pace Analytical Services , LLC - East Longmeadow, Ma FLAG/QUALIFIER SUMMARY *QC result is outside of established limits. †Wide recovery limits established for difficult compound . ‡Wide RPD limits established for difficult compound. #Data exceeded client recommended or regulatory level Percent recoveries and relative percent differences (RPDs) are determined by the software using values in the calculation which have not been rounded. No results have been blank subtracted unless specified in the case narrative section. RL Reporting Limit is at the level of quantitation (LOQ) DL Detection Limit is the lower limit of detection determined by the MDL study MCL Maximum Contaminant Level ND Not Detected [TOC_1]Flag/Qualifier Summary[TOC] Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 25  Packet Pg. 449 of 489  39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Pace Analytical Services , LLC - East Longmeadow, Ma CertificationsAnalyte CERTIFICATIONS Certified Analyses included in this Report No certified Analyses included in this Report [TOC_1]Certifications[TOC] Pace Analytical Services, LLC - East Longmeadow, Ma, operates under the following certifications and accreditations: Code Description Number Expires Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 26  Packet Pg. 450 of 489  Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 27  Packet Pg. 451 of 489  Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 28  Packet Pg. 452 of 489  Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 29  Packet Pg. 453 of 489  Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 30  Packet Pg. 454 of 489  Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 31  Packet Pg. 455 of 489  L2601022 Pace Analytical Minnesota 10760348 223101 FIELD TURF (TASK 9) Client: Project Name: Project Number: 01/14/26 Eight Walkup Drive, Westborough, MA 01581-1019 Lab Number: Report Date: 508-898-9220 (Fax) 508-898-9193 800-624-9220 - www.alphalab.com 1700 Elm Street Minneapolis, MN 55414 Carolynne TroutATTN: ANALYTICAL REPORT (612) 607-6351Phone: The original project report/data package is held by Pace Analytical Services. This report/data package is paginated and should be reproduced only in its entirety. Pace Analytical Services holds no responsibility for results and/or data that are not consistent with the original. Certifications & Approvals: MA (M-MA086), NH NELAP (2064), CT (PH-0826), IL (200077), IN (C-MA-03), KY (KY98045), ME (MA00086), MD (348), NJ (MA935), NY (11148), NC (25700/666), OR (MA-1316), PA (68-03671), RI (LAO00065), TX (T104704476), VT (VT-0935), VA (460195), USDA (Permit #525-23-122-91930A1). Serial_No:01142612:02 Page 1 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 32  Packet Pg. 456 of 489  L2601022-01 L2601022-02 Lab Sample ID MAYFIELD-1 MAYFIELD-2 Client ID MN MN Sample Location 223101 FIELD TURF (TASK 9) 10760348 Project Name: Project Number: Lab Number: Report Date: L2601022 01/14/26 12/18/25 14:02 12/18/25 14:18 Collection Date/TimeMatrix Receive Date SOLID SOLID 01/08/26 01/08/26 Serial_No:01142612:02 Page 2 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 33  Packet Pg. 457 of 489  223101 FIELD TURF (TASK 9) 10760348 Project Name: Project Number: Lab Number: Report Date: L2601022 01/14/26 Case Narrative The samples were received in accordance with the Chain of Custody and no significant deviations were encountered during the preparation or analysis unless otherwise noted. Sample Receipt, Container Information, and the Chain of Custody are located at the back of the report. Results contained within this report relate only to the samples submitted under this Pace Lab Number and meet NELAP requirements for all NELAP accredited parameters unless otherwise noted in the following narrative. The data presented in this report is organized by parameter (i.e. VOC, SVOC, etc.). Sample specific Quality Control data (i.e. Surrogate Spike Recovery) is reported at the end of the target analyte list for each individual sample, followed by the Laboratory Batch Quality Control at the end of each parameter. Tentatively Identified Compounds (TICs), if requested, are reported for compounds identified to be present and are not part of the method/program Target Compound List, even if only a subset of the TCL are being reported. If a sample was re-analyzed or re-extracted due to a required quality control corrective action and if both sets of data are reported, the Laboratory ID of the re-analysis or re-extraction is designated with an "R" or "RE", respectively. When multiple Batch Quality Control elements are reported (e.g. more than one LCS), the associated samples for each element are noted in the grey shaded header line of each data table. Any Laboratory Batch, Sample Specific % recovery or RPD value that is outside the listed Acceptance Criteria is bolded in the report. In reference to questions H (CAM) or 4 (RCP) when "NO" is checked, the performance criteria for CAM and RCP methods allow for some quality control failures to occur and still be within method compliance. In these instances, the specific failure is not narrated but noted in the associated QC Outlier Summary Report, located directly after the Case Narrative. QC information is also incorporated in the Data Usability Assessment table (Format 11) of our Data Merger tool, where it can be reviewed in conjunction with the sample result, associated regulatory criteria and any associated data usability implications. Soil/sediments and solids are reported on a dry weight basis unless otherwise noted. Tissues are reported "as received" or on a wet weight basis, unless otherwise noted. Definitions of all data qualifiers and acronyms used in this report are provided in the Glossary located at the back of the report. HOLD POLICY - For samples submitted on hold, Pace's policy is to hold samples (with the exception of Air canisters) free of charge for 21 calendar days from the date the project is completed. After 21 calendar days, we will dispose of all samples submitted including those put on hold unless you have contacted your Pace Project Manager and made arrangements for Pace to continue to hold the samples. Air canisters will be disposed after 3 business days from the date the project is completed. Please contact Project Management at 800-624-9220 with any questions. Serial_No:01142612:02 Page 3 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 34  Packet Pg. 458 of 489  Case Narrative (continued) 223101 FIELD TURF (TASK 9) 10760348 Project Name: Project Number: Lab Number: Report Date: L2601022 01/14/26 Report Submission The laboratory does not hold certification for the analysis of Fluoride in the state of California. I, the undersigned, attest under the pains and penalties of perjury that, to the best of my knowledge and belief and based upon my personal inquiry of those responsible for providing the information contained in this analytical report, such information is accurate and complete. This certificate of analysis is not complete unless this page accompanies any and all pages of this report. Authorized Signature: Title: Technical Director/Representative Date: 01/14/26 Serial_No:01142612:02 Page 4 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 35  Packet Pg. 459 of 489  INORGANICS & MISCELLANEOUS Serial_No:01142612:02 Page 5 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 36  Packet Pg. 460 of 489  FF MAYFIELD-1Client ID: 12/18/25 14:02Date Collected: 01/08/26Date Received: Parameter Result Dilution Factor Matrix:Solid MNSample Location: L2601022-01Lab ID: Qualifier Units RL SAMPLE RESULTS Project Name: Project Number: Lab Number: Report Date: 223101 FIELD TURF (TASK 9) 10760348 L2601022 Field Prep: Date Analyzed Analytical Method Analyst Not Specified General Chemistry - Westborough Lab Fluoride ND mg/kg 110 01/11/26 07:18 121,4500F-BC DTH Date Prepared 01/11/26 03:01 01/14/26 MDL -- Sample Depth: Percent Solids: Results reported on an 'AS RECEIVED' basis. Serial_No:01142612:02 Page 6 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 37  Packet Pg. 461 of 489  FF MAYFIELD-2Client ID: 12/18/25 14:18Date Collected: 01/08/26Date Received: Parameter Result Dilution Factor Matrix:Solid MNSample Location: L2601022-02Lab ID: Qualifier Units RL SAMPLE RESULTS Project Name: Project Number: Lab Number: Report Date: 223101 FIELD TURF (TASK 9) 10760348 L2601022 Field Prep: Date Analyzed Analytical Method Analyst Not Specified General Chemistry - Westborough Lab Fluoride ND mg/kg 110 01/11/26 07:18 121,4500F-BC DTH Date Prepared 01/11/26 03:01 01/14/26 MDL -- Sample Depth: Percent Solids: Results reported on an 'AS RECEIVED' basis. Serial_No:01142612:02 Page 7 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 38  Packet Pg. 462 of 489  FF Parameter Result Dilution FactorQualifierUnitsRL Method Blank Analysis Batch Quality Control Project Name: Project Number: Lab Number: Report Date: 223101 FIELD TURF (TASK 9) 10760348 L2601022 Date Analyzed Analytical Method Analyst Date Prepared 01/14/26 Fluoride ND mg/kg 110 01/11/26 07:18 121,4500F-BC DTH01/11/26 03:01 General Chemistry - Westborough Lab for sample(s): 01-02 Batch: WG2163790-1 MDL -- Serial_No:01142612:02 Page 8 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 39  Packet Pg. 463 of 489  Fluoride 95 -80-120 - Parameter LCS %Recovery LCSD %Recovery %Recovery Limits RPD RPD Limits General Chemistry - Westborough Lab Associated sample(s): 01-02 Batch: WG2163790-2 Lab Control Sample Analysis Batch Quality Control Project Name: Project Number: Lab Number: Report Date: 223101 FIELD TURF (TASK 9) 10760348 L2601022 01/14/26 Qual Qual Qual Serial_No:01142612:02 Page 9 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 40  Packet Pg. 464 of 489  Fluoride ND 40 40 --70-130 - Parameter Native Sample MS Found MS %Recovery MSD Found MSD %Recovery Recovery Limits RPD RPD Limits General Chemistry - Westborough Lab Associated sample(s): 01-02 QC Batch ID: WG2163790-4 QC Sample: L2601020-01 Client ID: MS Sample 99.7 MS Added Matrix Spike Analysis Batch Quality Control Project Name: Project Number: Lab Number: Report Date: 223101 FIELD TURF (TASK 9) 10760348 L2601022 01/14/26 Qual Q Qual Qual Serial_No:01142612:02 Page 10 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 41  Packet Pg. 465 of 489  Fluoride ND ND mg/kg NC 20 Units RPDParameterNative Sample Duplicate Sample RPD Limits General Chemistry - Westborough Lab Associated sample(s): 01-02 QC Batch ID: WG2163790-3 QC Sample: L2601020-01 Client ID: DUP Sample 223101 FIELD TURF (TASK 9) 10760348 Project Name: Project Number: L2601022Lab Number: Report Date: Lab Duplicate Analysis Batch Quality Control 01/14/26 Qual Serial_No:01142612:02 Page 11 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 42  Packet Pg. 466 of 489  *Values in parentheses indicate holding time in days L2601022-01A L2601022-02A Plastic 120ml unpreserved Plastic 120ml unpreserved NA NA NA NA Y Y Absent Absent A Absent Cooler Custody Seal Cooler Information 223101 FIELD TURF (TASK 9) 10760348 F-4500(28),TS100() F-4500(28),TS100() Project Name: Project Number: L2601022Lab Number: Report Date: Sample Receipt and Container Information Container ID Container Type Cooler Temp deg C Pres Seal Container Information Analysis(*) 01/14/26 Were project specific reporting limits specified?YES Frozen Date/Time Final pH Initial pH Serial_No:01142612:02 Page 12 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 43  Packet Pg. 467 of 489  Report Format:Data Usability Report GLOSSARY Project Name: Project Number: Lab Number: Report Date: L2601022223101 FIELD TURF (TASK 9) 10760348 01/14/26 Acronyms DL EDL EMPC EPA LCS LCSD LFB LOD LOQ MDL MS MSD NA NC NDPA/DPA NI NP NR RL RPD SRM STLP TEF TEQ TIC Detection Limit: This value represents the level to which target analyte concentrations are reported as estimated values, when those target analyte concentrations are quantified below the limit of quantitation (LOQ). The DL includes any adjustments from dilutions, concentrations or moisture content, where applicable. (DoD report formats only.) Estimated Detection Limit: This value represents the level to which target analyte concentrations are reported as estimated values, when those target analyte concentrations are quantified below the reporting limit (RL). The EDL includes any adjustments from dilutions, concentrations or moisture content, where applicable. The use of EDLs is specific to the analysis of PAHs using Solid-Phase Microextraction (SPME). Estimated Maximum Possible Concentration: The concentration that results from the signal present at the retention time of an analyte when the ions meet all of the identification criteria except the ion abundance ratio criteria. An EMPC is a worst-case estimate of the concentration. Environmental Protection Agency. Laboratory Control Sample: A sample matrix, free from the analytes of interest, spiked with verified known amounts of analytes or a material containing known and verified amounts of analytes. Laboratory Control Sample Duplicate: Refer to LCS. Laboratory Fortified Blank: A sample matrix, free from the analytes of interest, spiked with verified known amounts of analytes or a material containing known and verified amounts of analytes. Limit of Detection: This value represents the level to which a target analyte can reliably be detected for a specific analyte in a specific matrix by a specific method. The LOD includes any adjustments from dilutions, concentrations or moisture content, where applicable. (DoD report formats only.) Limit of Quantitation: The value at which an instrument can accurately measure an analyte at a specific concentration. The LOQ includes any adjustments from dilutions, concentrations or moisture content, where applicable. (DoD report formats only.) Limit of Quantitation: The value at which an instrument can accurately measure an analyte at a specific concentration. The LOQ includes any adjustments from dilutions, concentrations or moisture content, where applicable. (DoD report formats only.) Method Detection Limit: This value represents the level to which target analyte concentrations are reported as estimated values, when those target analyte concentrations are quantified below the reporting limit (RL). The MDL includes any adjustments from dilutions, concentrations or moisture content, where applicable. Matrix Spike Sample: A sample prepared by adding a known mass of target analyte to a specified amount of matrix sample for which an independent estimate of target analyte concentration is available. For Method 332.0, the spike recovery is calculated using the native concentration, including estimated values. Matrix Spike Sample Duplicate: Refer to MS. Not Applicable. Not Calculated: Term is utilized when one or more of the results utilized in the calculation are non-detect at the parameter's reporting unit. N-Nitrosodiphenylamine/Diphenylamine. Not Ignitable. Non-Plastic: Term is utilized for the analysis of Atterberg Limits in soil. No Results: Term is utilized when 'No Target Compounds Requested' is reported for the analysis of Volatile or Semivolatile Organic TIC only requests. Reporting Limit: The value at which an instrument can accurately measure an analyte at a specific concentration. The RL includes any adjustments from dilutions, concentrations or moisture content, where applicable. Relative Percent Difference: The results from matrix and/or matrix spike duplicates are primarily designed to assess the precision of analytical results in a given matrix and are expressed as relative percent difference (RPD). Values which are less than five times the reporting limit for any individual parameter are evaluated by utilizing the absolute difference between the values; although the RPD value will be provided in the report. Standard Reference Material: A reference sample of a known or certified value that is of the same or similar matrix as the associated field samples. Semi-dynamic Tank Leaching Procedure per EPA Method 1315. Toxic Equivalency Factors: The values assigned to each dioxin and furan to evaluate their toxicity relative to 2,3,7,8-TCDD. Toxic Equivalent: The measure of a sample's toxicity derived by multiplying each dioxin and furan by its corresponding TEF and then summing the resulting values. Tentatively Identified Compound: A compound that has been identified to be present and is not part of the target compound list (TCL) for the method and/or program. All TICs are qualitatively identified and reported as estimated concentrations. - - - - - - - - - - - - - - - - - - - - - - - - Serial_No:01142612:02 Page 13 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 44  Packet Pg. 468 of 489  Report Format:Data Usability Report Project Name: Project Number: Lab Number: Report Date: L2601022223101 FIELD TURF (TASK 9) 10760348 01/14/26 Terms Analytical Method: Both the document from which the method originates and the analytical reference method. (Example: EPA 8260B is shown as 1,8260B.) The codes for the reference method documents are provided in the References section of the Addendum. Chlordane: The target compound Chlordane (CAS No. 57-74-9) is reported for GC ECD analyses. Per EPA,this compound "refers to a mixture of chlordane isomers, other chlorinated hydrocarbons and numerous other components." (Reference: USEPA Toxicological Review of Chlordane, In Support of Summary Information on the Integrated Risk Information System (IRIS), December 1997.) Difference: With respect to Total Oxidizable Precursor (TOP) Assay analysis, the difference is defined as the Post-Treatment value minus the Pre-Treatment value. Final pH: As it pertains to Sample Receipt & Container Information section of the report, Final pH reflects pH of container determined after adjustment at the laboratory, if applicable. If no adjustment required, value reflects Initial pH. Frozen Date/Time: With respect to Volatile Organics in soil, Frozen Date/Time reflects the date/time at which associated Reagent Water- preserved vials were initially frozen. Note: If frozen date/time is beyond 48 hours from sample collection, value will be reflected in 'bold'. Gasoline Range Organics (GRO): Gasoline Range Organics (GRO) results include all chromatographic peaks eluting from Methyl tert butyl ether through Naphthalene, with the exception of GRO analysis in support of State of Ohio programs, which includes all chromatographic peaks eluting from Hexane through Dodecane. Initial pH: As it pertains to Sample Receipt & Container Information section of the report, Initial pH reflects pH of container determined upon receipt, if applicable. PAH Total: With respect to Alkylated PAH analyses, the 'PAHs, Total' result is defined as the summation of results for all or a subset of the following compounds: Naphthalene, C1-C4 Naphthalenes, 2-Methylnaphthalene, 1-Methylnaphthalene, Biphenyl, Acenaphthylene, Acenaphthene, Fluorene, C1-C3 Fluorenes, Phenanthrene, C1-C4 Phenanthrenes/Anthracenes, Anthracene, Fluoranthene, Pyrene, C1-C4 Fluoranthenes/Pyrenes, Benz(a)anthracene, Chrysene, C1-C4 Chrysenes, Benzo(b)fluoranthene, Benzo(j)+(k)fluoranthene, Benzo(e)pyrene, Benzo(a)pyrene, Perylene, Indeno(1,2,3-cd)pyrene, Dibenz(ah)+(ac)anthracene, Benzo(g,h,i)perylene. If a 'Total' result is requested, the results of its individual components will also be reported. PFAS Total: With respect to PFAS analyses, the 'PFAS, Total (5)' result is defined as the summation of results for: PFHpA, PFHxS, PFOA, PFNA and PFOS. In addition, the 'PFAS, Total (6)' result is defined as the summation of results for: PFHpA, PFHxS, PFOA, PFNA, PFDA and PFOS. For MassDEP DW compliance analysis only, the 'PFAS, Total (6)' result is defined as the summation of results at or above the RL. Note: If a 'Total' result is requested, the results of its individual components will also be reported. Total: With respect to Organic analyses, a 'Total' result is defined as the summation of results for individual isomers or Aroclors. If a 'Total' result is requested, the results of its individual components will also be reported. This is applicable to 'Total' results for methods 8260, 8081 and 8082. Data Qualifiers A B C D E F G H I J M - - - - - - - - - - - Spectra identified as "Aldol Condensates" are byproducts of the extraction/concentration procedures when acetone is introduced in the process. The analyte was detected above the reporting limit in the associated method blank. Flag only applies to associated field samples that have detectable concentrations of the analyte at less than ten times (10x) the concentration found in the blank. For MCP-related projects, flag only applies to associated field samples that have detectable concentrations of the analyte at less than ten times (10x) the concentration found in the blank. For DOD-related projects, flag only applies to associated field samples that have detectable concentrations of the analyte at less than ten times (10x) the concentration found in the blank AND the analyte was detected above one-half the reporting limit (or above the reporting limit for common lab contaminants) in the associated method blank. For NJ-Air- related projects, flag only applies to associated field samples that have detectable concentrations of the analyte above the reporting limit. For NJ-related projects (excluding Air), flag only applies to associated field samples that have detectable concentrations of the analyte, which was detected above the reporting limit in the associated method blank or above five times the reporting limit for common lab contaminants (Phthalates, Acetone, Methylene Chloride, 2-Butanone). Co-elution: The target analyte co-elutes with a known lab standard (i.e. surrogate, internal standards, etc.) for co-extracted analyses. Concentration of analyte was quantified from diluted analysis. Flag only applies to field samples that have detectable concentrations of the analyte. Concentration of analyte exceeds the range of the calibration curve and/or linear range of the instrument. The ratio of quantifier ion response to qualifier ion response falls outside of the laboratory criteria. Results are considered to be an estimated maximum concentration. The concentration may be biased high due to matrix interferences (i.e, co-elution) with non-target compound(s). The result should be considered estimated. The analysis of pH was performed beyond the regulatory-required holding time of 15 minutes from the time of sample collection. The lower value for the two columns has been reported due to obvious interference. Estimated value. This represents an estimated concentration for Tentatively Identified Compounds (TICs). Reporting Limit (RL) exceeds the MCP CAM Reporting Limit for this analyte. 1 The reference for this analyte should be considered modified since this analyte is absent from the target analyte list of the original method. Footnotes Serial_No:01142612:02 Page 14 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 45  Packet Pg. 469 of 489  Report Format:Data Usability Report Project Name: Project Number: Lab Number: Report Date: L2601022223101 FIELD TURF (TASK 9) 10760348 01/14/26 Data Qualifiers ND NJ P Q R RE S V Z - - - - - - - - - Not detected at the reporting limit (RL) for the sample. Presumptive evidence of compound. This represents an estimated concentration for Tentatively Identified Compounds (TICs), where the identification is based on a mass spectral library search. The RPD between the results for the two columns exceeds the method-specified criteria. The quality control sample exceeds the associated acceptance criteria. For DOD-related projects, LCS and/or Continuing Calibration Standard exceedences are also qualified on all associated sample results. Note: This flag is not applicable for matrix spike recoveries when the sample concentration is greater than 4x the spike added or for batch duplicate RPD when the sample concentrations are less than 5x the RL. (Metals only.) Analytical results are from sample re-analysis. Analytical results are from sample re-extraction. Analytical results are from modified screening analysis. The surrogate associated with this target analyte has a recovery outside the QC acceptance limits. (Applicable to MassDEP DW Compliance samples only.) The batch matrix spike and/or duplicate associated with this target analyte has a recovery/RPD outside the QC acceptance limits. (Applicable to MassDEP DW Compliance samples only.) Serial_No:01142612:02 Page 15 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 46  Packet Pg. 470 of 489  Pace Analytical Services performs services with reasonable care and diligence normal to the analytical testing laboratory industry. In the event of an error, the sole and exclusive responsibility of Pace Analytical Services shall be to re-perform the work at it's own expense. In no event shall Pace Analytical Services be held liable for any incidental, consequential or special damages, including but not limited to, damages in any way connected with the use of, interpretation of, information or analysis provided by Pace Analytical Services. We strongly urge our clients to comply with EPA protocol regarding sample volume, preservation, cooling, containers, sampling procedures, holding time and splitting of samples in the field. LIMITATION OF LIABILITIES 121 Standard Methods for the Examination of Water and Wastewater. APHA-AWWA-WEF. Standard Methods Online. Project Name: Project Number: Lab Number: Report Date: L2601022223101 FIELD TURF (TASK 9) 10760348 REFERENCES 01/14/26 Serial_No:01142612:02 Page 16 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 47  Packet Pg. 471 of 489  ENV-FORM-WES2-0065 v02 Certificate/Approval Program Summary Qualtrax ID: 335524 Effective Date: 01/06/26 Page 1 of 2 Pace® Analytical Services, LLC (PAS) Certification Information The following analytes are not included in our Primary NELAP Scope of Accreditation: PAS-WES2 Westborough Facility – 8 Walkup Dr. Westborough, MA 01581 EPA 624.1: m/p-xylene, o-xylene, Naphthalene EPA 625.1: alpha-Terpineol EPA 8260D: NPW: 1,2,4,5-Tetramethylbenzene; 4-Ethyltoluene; SCM: Iodomethane (methyl iodide), 1,2,4,5-Tetramethylbenzene; 4-Ethyltoluene. EPA 8270E: NPW: Dimethylnaphthalene,1,4-Diphenylhydrazine, alpha-Terpineol, Azobenzene; SCM: Dimethylnaphthalene,1,4-Diphenylhydrazine. SM4500: NPW: Amenable Cyanide; SCM: Total Phosphorus, TKN, NO2, NO3. PAS-MANS Mansfield Facility – 320 Forbes Blvd. Mansfield, MA 02048 SM 2540D: TSS. Biological Tissue Matrix: EPA 3050B PAS-MAN1 Mansfield Facility – 120 Forbes Blvd. Mansfield, MA 02048 EPA TO-15: Halothane, 2,4,4-Trimethyl-2-pentene, 2,4,4-Trimethyl-1-pentene, Thiophene, 2-Methylthiophene, 3-Methylthiophene, 2-Ethylthiophene, 1,2,3-Trimethylbenzene, Indan, Indene, 1,2,4,5-Tetramethylbenzene, Benzothiophene, 1-Methylnaphthalene. MADEP-APH. PAS-ELON East Longmeadow Facility – 39 Spruce Street East Longmeadow, MA 01028 EPA 524.2: 1,3,5-Trichlorobenzene, m/p-Xylene, o-xylene. EPA 625.1: 1,2-Dichlorobenzene, 1,3-Dichlorobenzene, 1,4-Dichlorobenzene, N-Nitrosodiphenylamine. EPA 8081B NPW and SCM: Alachlor, Endrin Ketone, Hexachlorobenzene. EPA 8260D NPW: Tetrahydrofuran, 1,3,5-Trichlorobenzene; SCM: TAME, TBEE, Diethyl ether, DIPE, Tetrahydrofuran. 1,3,5-Trichlorobenzene, Freon- 113. EPA 8270E: NPW: Carbazole, 1-Methylnaphthalene, Pentachloronitrobenzene; SCM: Carbazole, 1-Methylnaphthalene. EPA TO-13: Air: Benzo(e)pyrene, 1-Methylnaphthalene, 2-Methylnaphthalene, Perylene. EPA TO-4A Pesticide Air: delta-BHC, Endosulfan I, Endosulfan II, Endosulfan Sulfate, Endrin, Endrin Aldehyde, Endrin Ketone, Hexachlorobenzene, Methoxychlor. SM4500: NPW: Amenable Cyanide; SCM: Total Phosphorus, TKN, NH3, NECi: NO2, NO3, ASTMD516. The following test method is not included in our New Jersey Secondary NELAP Scope of Accreditation: PAS-MANS Mansfield Facility – 320 Forbes Blvd. Mansfield, MA 02048 Determination of Selected Perfluorinated Alkyl Substances by Solid Phase Extraction and Liquid Chromatography/Tandem Mass Spectrometry Isotope Dilution (via Alpha SOP 23528) The following analytes are included in our Massachusetts DEP Scope of Accreditation: PAS-WES2 Westborough Facility – 8 Walkup Dr. Westborough, MA 01581 Drinking Water EPA 300.0: Chloride, Nitrate-N, Fluoride, Sulfate; EPA 353.2: Nitrate-N, Nitrite-N; SM4500NO3-F: Nitrate-N, Nitrite-N; SM4500F-C, SM4500CN-CE, EPA 180.1, SM2130B, SM4500Cl-D, SM2320B, SM2540C, SM4500H-B, SM4500NO2-B EPA 524.2: THMs and VOCs; EPA 504.1: EDB, DBCP. Microbiology: SM9215B; SM9223-P/A, SM9223B-Colilert-QT,SM9222D. Non-Potable Water SM4500H,B, EPA 120.1, SM2510B, SM2540C, SM2320B, SM4500CL-E, SM4500F-BC, SM4500NH3-BH: Ammonia-N and Kjeldahl-N, EPA 350.1: Ammonia-N, LACHAT 10-107-06-1-B: Ammonia-N, EPA 351.1, SM4500NO3-F, EPA 353.2: Nitrate-N, SM4500P-E, SM4500P-B, E, SM4500SO4-E, SM5220D, EPA 410.4, SM5210B, SM5310C, SM4500CL-G, EPA 1664, EPA 420.1, SM4500-CN-CE, SM2540D, EPA 300: Chloride, Sulfate, Nitrate. EPA 624.1: Volatile Halocarbons & Aromatics, EPA 608.3: Chlordane, Toxaphene, Aldrin, alpha-BHC, beta-BHC, gamma-BHC, delta-BHC, Dieldrin, DDD, DDE, DDT, Endosulfan I, Endosulfan II, Endosulfan sulfate, Endrin, Endrin Aldehyde, Heptachlor, Heptachlor Epoxide, PCBs EPA 625.1: SVOC (Acid/Base/Neutral Extractables). Microbiology: SM9223B-Colilert-QT; Enterolert-QT. Serial_No:01142612:02 Page 17 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 48  Packet Pg. 472 of 489  ENV-FORM-WES2-0065 v02 Certificate/Approval Program Summary Qualtrax ID: 335524 Effective Date: 01/06/26 Page 2 of 2 Pace® Analytical Services, LLC (PAS) PAS-MANS Mansfield Facility – 320 Forbes Blvd. Mansfield, MA 02048 Drinking Water EPA 200.7: Al, Ba, Cd, Cr, Cu, Fe, Mn, Ni, Na, Ag, Ca, Zn. EPA 200.8: Al, Sb, As, Ba, Be, Cd, Cr, Cu, Pb, Mn, Ni, Se, Ag, TL, Zn. EPA 245.1 Hg. EPA 522, EPA 537.1. Non-Potable Water EPA 200.7: Al, Sb, As, Be, Cd, Ca, Cr, Co, Cu, Fe, Pb, Mg, Mn, Mo, Ni, K, Se, Ag, Na, Sr, TL, Ti, V, Zn. EPA 200.8: Al, Sb, As, Be, Cd, Ca, Cr, Cu, Fe, Pb, Mg, Mn, Ni, K, Se, Ag, Na, TL, Zn. EPA 245.1: Hg. EPA 245.7: Hg. SM2340B PAS-ELON East Longmeadow Facility – 39 Spruce Street East Longmeadow, MA 01028 Drinking Water EPA 300.0: NO3, NO2, Fl, Cl, SO4. NECI Reductase: NO3, NO2. SM4500F-C, SM4500Cl-B, ASTM D516, SM4500CN-C,E, EPA 180.1, SM2320B, SM 2540C, SM4500H-B, SM4500SO4-E. EPA 537.1; EPA 524.2: THMs and VOCs; EPA 504.1: EDB, DBCP. Microbiology: SM9223-P/A: TC/EC; SM9223B-Colilert-enumeration: TC/EC; HPC-Simplate. Non-Potable Water SM4500H-B, SM2510B, SM2540C, SM2320B, SM4500Cl-B, ASTMD516, SM4500NH3-B, C, EPA 350.1, NECi: NO3, SM4500NH3-B, C: TKN, SM4500P-E: Ortho Phosphate, SM4500P-B, E: Total Phosphorus, EPA 410.4, SM5210B, SM5310C, SM4500CN-C, E, SM2540D, SM4500Cl-G, SM4500SO4-E, EPA 1664, EPA 420.1, EPA 300.0: Cl, SO4, NO3. EPA 624.1: Volatile Halocarbons, Volatile Aromatics. EPA 608.3: Chlordane, Toxaphene, Aldrin, Alpha-BHC, Beta-BHC, Gamma-BHC, Delta-BHC, Dieldrin, DDD, DDE, DDT, Endosulfan I, Endosulfan II, Endosulfan Sulfate, Endrin, Endrin Aldehyde, Heptachlor, Heptachlor Epoxide, PCBs. EPA 625.1: SVOC-Acid Extractables and Base/Neutrals Microbiology: SM9223B-Colilert: E. coli (Ambient and Wastewater), SM9223B-Colilert-18: Fecal Coliform (Wastewater). Certification IDs: PAS-WES2 Westborough Facility – 8 Walkup Dr. Westborough, MA 01581 CT PH-0826, IL 200077, IN C-MA-03, KY kY98045, ME MA00086, MD 348, MA M-MA086, NH 2064, NJ MA935, NY 11148, NC (DW) 25700, NC (NPW/SCM) 666, OR MA-1316, PA 68-03671, RI LAO00065, TX T104704476, VT VT-0935, VA 460195. PAS-MANS Mansfield Facility – 320 Forbes Blvd. Mansfield, MA 02048 ANAB/DoD L2474, CA 3117, CO MA00030, CT PH-0825, IL 200081, IN C-MA-04, KY KY98046, LA 85084, ME MA00030, MD 350, MA M-MA00030, MI 9110, MN 025-999-495, NH 2062, NJ MA015, NY 11627, NC (NPW/SCM) 685, OR MA-0262, PA 68-02089, RI LAO00299, TX T-104704419, UT MA00030, VT VT-0015, VA 460194, WA C954. PAS-MAN1 Mansfield Air Lab Facility – 120 Forbes Blvd. Mansfield, MA 02048 ANAB/DoD L2474, LA 245052, ME MA01156, MN 025-999-498, NH 2249, NJ MA025, NY 12191, OR 4203, TX T104704583, VA 460311, WA C1104. PAS-ELON East Longmeadow Facility – 39 Spruce St. East Longmeadow, MA 01028 CT PH-0821, ME MA00100, MI 9100, NC (DENR) 652, NC (DW) 25703, MA M-MA100, NH (Secondary) 2516, NH (Primary) 2557, NJ MA007, NY 10899, PA 68-05812, RI LAO00373, VA 460217, VT-255716, WV DEP 419, WV-DW 9979C, LA 05130, LA-DW LA042, MD-DW 373, OH 87781. For a complete listing of analytes and methods, please contact your Project Manager. Serial_No:01142612:02 Page 18 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 49  Packet Pg. 473 of 489  Serial_No:01142612:02 Page 19 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 50  Packet Pg. 474 of 489  Serial_No:01142612:02 Page 20 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 51  Packet Pg. 475 of 489  Serial_No:01142612:02 Page 21 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 52  Packet Pg. 476 of 489  Sample Delivery Group SummarySample Delivery Group Summary Pace Job Number :L2601022 Received :08-JAN-2026 Reviewer :Harmony Evans Account Name :Pace Analytical Minnesota Project Number :10760348 Project Name :223101 FIELD TURF (TASK 9) Delivery Information Samples Delivered By :Express Ship FedEx (424355846224) Chain of Custody :Present Cooler Information Cooler Seal/Seal#Preservation Temperature(°C)Additional Information A Absent/Ice 4.8 Condition Information 1) All samples on COC received?YES 2) Extra samples received?NO 3) Are there any sample container discrepancies?NO 4) Are there any discrepancies between COC & sample labels?NO 5) Are samples in appropriate containers for requested analysis?YES 6) Are samples properly preserved for requested analysis?YES 7) Are samples within holding time for requested analysis?YES 8) All sampling equipment returned?NA Volatile Organics/VPH 1) Reagent Water Vials Frozen by Client?NA Serial_No:01142612:02 Page 22 of 22 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 53  Packet Pg. 477 of 489  Field Turf_Mayfield_a022326m Appendix C Data Validation Checklist: Fluorine Analysis in Solid Samples Laboratory Report No. 10760348 Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 54  Packet Pg. 478 of 489  C-1 Field Turf_Mayfield_a022326m Project Location: Mayfield Soccer Complex, Palo Alto, CA Sampling Date: 12/18/2025 Matrices: Solid Methods: Total Fluorine (TF) by Combustion Ion Chromatography (CIC) Inorganic Fluoride (IF) by Method 121,4500F-BC Laboratory: Pace Labs Report or Job ID: 10760348 Data Validation Level: Level 2 Initial Date Validation Reviewer/Completion Date: William Dowd – 1/20/2025 Senior Data Validation Reviewer/Completion Date: Stephanie Kukolich – 1/23/2026 This Level 2 data validation checklist provides the findings of a data quality review of the laboratory deliverables for the site and samples referenced below. Raw data were not reviewed as part of this Level 2 review; rather, data reporting forms were reviewed to determine whether validation criteria were met. The data validation review was conducted according to procedures defined in the Sampling and Analysis Plan (SAP) and with reference to the requirements listed in the United States Environmental Protection Agency (US EPA) "Guidance on Environmental Data Verification and Data Validation" (US EPA, 2002) and the professional judgment of the reviewers. General sampling and analysis information is provided below, and a summary of the samples validated are provided in Table C.1. The following data qualifiers have been used to qualify the data, when appropriate. J+ = Data result is estimated due to potential high bias. J- = Data result is estimated due to potential low bias. J = Data result is estimated and may be inaccurate or imprecise. UJ = Data result is not detected above the level of the associated value. The result is estimated and may be inaccurate or imprecise. X = Exclusion of data is recommended. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 55  Packet Pg. 479 of 489  C-2 Field Turf_Mayfield_a022326m Table C.1 Sample Summary – Laboratory Report No. 10760348 Client Sample ID Laboratory Sample ID Matrix Sample Description or Parent Sample Date Collected Date Received Date Prepared Date Analyzed Batch # TF by CIC Mayfield-1 26A0197-01 Solid – 12/18/2025 1/8/2026 1/8/2026 1/8/2026 B420497 Mayfield-2 26A0197-02 Solid FD of Mayfield-1 12/18/2025 1/8/2026 1/8/2026 1/8/2026 B420497 IF by Method 121,4500F-BC Mayfield-1 L2601022-01 Solid – 12/18/2025 1/8/2026 1/11/2026 1/11/2026 WG2163790 Mayfield-2 L2601022-02 Solid FD of Mayfield-1 12/18/2025 1/8/2026 1/11/2026 1/11/2026 WG2163790 Notes: CIC = Combustion Ion Chromatography; FD = Field Duplicate; IF = Inorganic Fluoride; TF = Total Fluorine. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 56  Packet Pg. 480 of 489  C-3 Field Turf_Mayfield_a022326m Executive Summary Overall Summary of Data Usability A. Summary of Technical Usability No technical issues were noted during the data validation review. B. Technical Issues Affecting Accuracy No technical issues affecting accuracy were noted during the data validation review. C. Technical Issues Affecting Sensitivity No technical issues affecting sensitivity were noted during the data validation review. D. Completeness No technical issues affecting completeness were noted during the data validation review. E. Other Technical Issues No additional technical issues were identified during the data validation review. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 57  Packet Pg. 481 of 489  C-4 Field Turf_Mayfield_a022326m C.1 Total Fluorine by Combustion Ion Chromatography (CIC) C.1.1 Chain-of-Custody (COC) and Sample Documentation Completeness Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 1. Were safe storage and preservation requirements met? If temperature >6°C, then J-flag detects, and UJ-flag nondetects. X 2. Were all COC records signed, indicating that COC was maintained for all samples? X 3. Were there any problems noted in the laboratory data package concerning the condition of samples upon receipt? X The laboratory noted that the sample containers lacked dates or times. However, based on communications with the samplers, no qualifiers are necessary due to the sample container labels. 4. Were the COCs filled out correctly? X 5. Were field QC samples included? X Notes: COC = Chain of Custody; N/A = Not Applicable; QC = Quality Control. C.1.2 Sample Result Review Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 6. Was a narrative summary of QA or sample problems provided by the laboratory? X 7. Are the units correct? X Notes: N/A = Not Applicable; QA = Quality Assurance. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 58  Packet Pg. 482 of 489  C-5 Field Turf_Mayfield_a022326m C.1.3 Blanks Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 8. Was a method blank (MB) extracted with each analysis batch (i.e., 1 per 20 samples, per batch, per matrix)? X 9. Were detections in the samples below the MB contamination level? If yes, U-flag positive sample results reported at the RL, and J+-flag results >RL but <5X the MB concentration. No flags are assigned if the sample result is >RL and >5X the MB concentration. X Notes: N/A = Not Applicable; RL = Reporting Limit. C.1.4 Field Duplicates Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 10. Were field duplicates collected in association with the samples in this data report? X 11. If so, was precision deemed acceptable (i.e., <50% RPD in aqueous matrices and 100% in soil matrices)? Analytes with RPDs outside acceptable limits will be J-flagged (detects) or UJ-flagged (nondetects) when sample results are >5X the average RL. If the sample results are ≤5X the average RL, then precision is based on the absolute difference between duplicate results. J-flag sample results whenever the absolute difference is greater than the average RL. X Notes: N/A = Not Applicable; RL = Reporting Limit; RPD = Relative Percent Different. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 59  Packet Pg. 483 of 489  C-6 Field Turf_Mayfield_a022326m C.1.5 Laboratory Control Samples (LCSs) and Laboratory Control Sample Duplicates (LCSDs) Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 12. Were laboratory control samples (LCSs) and laboratory control sample duplicates (LCSDs) analyzed at the proper frequency and were the recoveries summarized? LCSs and LCSDs should be prepared per 20 samples, per batch, per matrix. X 13. Were LCS and LCSDs recoveries within the acceptable criteria? If the LCS or LCSDs percentage recoveries were greater than the upper control limit, J+-flag detects for the analyte in the associated samples. Nondetects should not be qualified. If the LCS or LCSDs percentage recoveries were less than the lower control limit, flag detects for the analyte in the associated samples as estimated with a negative bias (J-) and flag nondetects as X. X Note: N/A = Not Applicable. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 60  Packet Pg. 484 of 489  C-7 Field Turf_Mayfield_a022326m C.2 Inorganic Fluoride by Method 121,4500F-BC C.2.1 Chain-of-Custody (COC) and Sample Documentation Completeness Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 14. Were safe storage and preservation requirements met? If temperature >6°C, then J-flag detects, and UJ-flag nondetects. X 15. Were all COC records signed, indicating that COC was maintained for all samples? X 16. Were there any problems noted in the laboratory data package concerning the condition of samples upon receipt? X The laboratory noted that the sample containers lacked dates or times. However, based on communications with the samplers, no qualifiers are necessary due to the sample container labels. 17. Were the COCs filled out correctly? X 18. Were field QC samples included? X Notes: COC = Chain of Custody; N/A = Not Applicable; QC = Quality Control. C.2.2 Sample Result Review Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 19. Was a narrative summary of QA or sample problems provided by the laboratory? X 20. Are the units correct? X Notes: N/A = Not Applicable; QA = Quality Assurance. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 61  Packet Pg. 485 of 489  C-8 Field Turf_Mayfield_a022326m C.2.3 Blanks Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 21. Was a method blank (MB) extracted with each analysis batch (i.e., 1 per 20 samples, per batch, per matrix)? X 22. Were detections in the samples below the MB contamination level? If yes, U-flag positive sample results reported at the RL, and J+-flag results >RL but <5X the MB concentration. No flags are assigned if the sample result is >RL and >5X the MB concentration. X Notes: N/A = Not Applicable; RL = Reporting Limit. C.2.4 Field Duplicates Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 23. Were field duplicates collected in association with the samples in this data report? X 24. If so, was precision deemed acceptable (i.e., <50% RPD in aqueous matrices and 100% in soil matrices)? Analytes with RPDs outside acceptable limits will be J-flagged (detects) or UJ-flagged (nondetects) when sample results are >5X the average RL. If the sample results are ≤5X the average RL, then precision is based on the absolute difference between duplicate results. J-flag sample results whenever the absolute difference is greater than the average RL. X Notes: N/A = Not Applicable; RL = Reporting Limit; RPD = Relative Percent Different. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 62  Packet Pg. 486 of 489  C-9 Field Turf_Mayfield_a022326m C.2.5 Laboratory Control Samples (LCSs) and Laboratory Control Sample Duplicates (LCSDs) Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 25. Were laboratory control samples (LCSs) and laboratory control sample duplicates (LCSDs) analyzed at the proper frequency and were the recoveries summarized? LCSs and LCSDs should be prepared per 20 samples, per batch, per matrix. X Only one LCS was reported in the data package. Because the LCS met the recovery criteria, and all other data validation criteria were met, no actions were taken. 26. Were LCS and LCSDs recoveries within the acceptable criteria? If the LCS or LCSDs percentage recoveries were greater than the upper control limit, J+-flag detects for the analyte in the associated samples. Nondetects should not be qualified. If the LCS or LCSDs percentage recoveries were less than the lower control limit, flag detects for the analyte in the associated samples as estimated with a negative bias (J-) and flag nondetects as X. X Note: N/A = Not Applicable. C.2.6 Matrix Spike/Matrix Spike Duplicate (MS/MSD) Analysis Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 27. Were matrix spikes (MSs)/matrix spike duplicates (MSDs) analyzed at the appropriate frequency and were the recoveries summarized? X It appears that the reported MS was not associated with the Mayfield Soccer Complex FieldTurf samples in this data package. The laboratory listed the QC sample ID associated with the MS as "L2601020-01," whereas the laboratory sample ID associated with the Mayfield Soccer Complex FieldTurf samples was listed as "L2601022." No actions were taken except to note this discrepancy. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 63  Packet Pg. 487 of 489  C-10 Field Turf_Mayfield_a022326m Review Questions Yes No N/A Sample and Analytes Affected/Comments Flag 28. Are the MS/MSD recoveries within the defined acceptance criteria? If the MS or MSD percentage recoveries were greater than the upper control limit, flag detects for the analyte in the associated parent sample as estimated J+. Nondetects should not be qualified. If the MS or MSD percentage recoveries were less than the lower acceptance limit but ≥10%, flag detects for the analyte in the associated parent sample as estimated J- and nondetects as estimated UJ. If the percentage recoveries were <10%, flag detects for the analyte in the associated parent sample as estimated J- and nondetects as X. X 29. Was the RPD for the MS/MSD summarized? X 30. Is the MS/MSD RPD within the defined acceptance criteria? If the RPD was above the accepted RPD criteria, flag detects for the analyte in the associated sample(s) as J and nondetects as estimated UJ. X Notes: N/A = Not Applicable; QC = Quality Control; RPD = Relative Percent Difference. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 64  Packet Pg. 488 of 489  C-11 Field Turf_Mayfield_a022326m References US EPA. 2002. "Guidance on Environmental Data Verification and Data Validation (Final)." Office of Environmental Information. EPA/240/R-02/004, EPA QA/G-8, 95p., November. Item AA2 Attachment A - Mayfield Soccer Complex Total Organic Fluorine (TOF) Results        Item AA2: Staff Report Pg. 65  Packet Pg. 489 of 489