HomeMy WebLinkAboutStaff Report 2603-6092CITY OF PALO ALTO
CITY COUNCIL
Special Meeting
Monday, April 20, 2026
Council Chambers & Hybrid
5:30 PM
Agenda Item
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,
Public Comment
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
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
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
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
***NOT YET APPROVED***
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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.
***NOT YET APPROVED***
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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.
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***NOT YET APPROVED***
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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 No. 6. Page 1 of 2
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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 No. 6. Page 2 of 2
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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
From:herb
To:Council, City; Clerk, City
Cc:Planning Commission
Subject:August 20, 2026 City Council Meeting, Agenda item #6: Housing Element Site Inventory Modifications
Date:Friday, April 17, 2026 4:59:24 PM
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
AUGUST 20, 2026 CITY COUNCIL MEETING
AGENDA ITEM #6: HOUSING ELEMENT SITE INVENTORY MODIFICATIONS
I urge you to remove this item from the meeting's ConsentCalendar, and to direct staff to refer to the Planning andTransportation Commission all proposed modifications to theHousing Element Site Inventory so that the Commission can holda public hearing on the subject and make a recommendation tothe City Council which would then hold a public hearing on thesubject before making a decision.
The only reason there might be an urgency to justify the CityCouncil giving the Director of Planning and DevelopmentServicesthe right to make such modifications is if theDirector is aware of a specific project or projects that wouldbenefit from the modifications and would need the Director toact quickly.
If there are any such projects, then the request to modify theHousing Element Site Inventory should come from theapplicant(s) who would benefit from the modifications insteadof from the Director.
Thank you for your consideration of these comments.
Herb Borock
Cc: Planning and Transportation Commission