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HomeMy WebLinkAboutStaff Report 2601-5873CITY OF PALO ALTO CITY COUNCIL Special Meeting Monday, April 20, 2026 Council Chambers & Hybrid 5:30 PM     Agenda Item     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. Public Comment, Staff Presentation 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 percent or more damaged, decayed, or deteriorated, constituted fire hazards, and could not be repaired to eliminate code violations. BACKGROUND • 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 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 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. 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 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 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 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 J. Declaration of George Hoyt, Chief Building Official APPROVED BY: 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. 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. 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. 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. 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: 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 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, 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 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. 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, 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 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 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 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 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 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. 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)) 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. 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) 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) 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. 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. 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 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 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: 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. 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 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. 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. 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. 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. 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; 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, 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 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: _______________________________ _____________________________________________ 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 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 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 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 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) • 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) • 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 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 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. • 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 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. 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 1 of 163 Photographic Evidence of Code Violations at 531 Stanford Avenue 2 of 163 Section I - 531 Stanford Avenue Exterior and Perimeter 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) 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. 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) 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. 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. 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 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). 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. 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. 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. 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. 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. 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. 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. 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) 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) 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) 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) 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) 22 of 163 23 of 163 Section II: 531 Stanford Avenue Interior Floors 1, 2, 3, & Roof 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)) 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) 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. 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) 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. 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. 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)) 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)) 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) 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. 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) 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) 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) 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) 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) 39 of 163 PAMC Violation: Electrical Panel Not labeled properly. 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) 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) 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) 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) 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)) 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) 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) 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) 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. 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. 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. . 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) 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) 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) 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) 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) 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) 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) 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) 59 of 163 PAMC Violation: View of miscellaneous items that were repurposed from when the buildings were used as a hotel. 60 of 163 PAMC Violation: View of miscellaneous items that were repurposed from when the buildings were used as a hotel. 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)) 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)) 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) 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)) 65 of 163 PAMC Violation: Unpermitted door hardware, adapted to add a lock. 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. 67 of 163 PAMC Violation: Improper exit signage. 68 of 163 PAMC Violation: Improper exit signage. 69 of 163 PAMC Violation: Improper exit signage. 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. 71 of 163 PAMC Violation: Miscellaneous items impeding emergency egress. 72 of 163 PAMC Violation: Miscellaneous items located in the “former lobby”. Room used as storage. 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)) 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. 75 of 163 PAMC Violation: Room used as storage. Represents combustible load. (CFC sec. 311.3) 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)) 77 of 163 PAMC Violation: Unpermitted construction, Improper installation of A/C unit. Similar conditions present throughout all converted hotel rooms. 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. 79 of 163 PAMC Violation: Expired Fire Extinguisher. Most of the fire extinguishers present throughout the entire buildings were expired. 80 of 163 Section III: 531 Stanford Avenue Basement 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) 82 of 163 PAMC Violation: Improper use of signage in basement/garage. No exit signage was present in the garage area. (CBC 1013.1) 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)) 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)) 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)) 86 of 163 PAMC Violation: Improper storage blocking access to emergency shut off. 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. 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. 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. 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. 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. 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) 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. 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) 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. 96 of 163 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. 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. 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. 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. 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) 102 of 163 PAMC Violation: Unapproved use of indoor bike storage. 103 of 163 PAMC Violation: Visible corrosion on piping. 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) 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) 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) 107 of 163 PAMC Violation: Unknown substances stored in closed storage equipment room. 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)) 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) 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. 111 of 163 PAMC Violation: Unpermitted and improperly installed dilapidated lighting fixture. 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. 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. 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) 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) 116 of 163 PAMC Violation: Improper storage of portable gas container (filled with gas) and paint thinner. 117 of 163 PAMC Violation: Unsafe installation of electrical wires in basement. (CBC § 114.1; PAMC § 16.04.225) 118 of 163 PAMC Violation: Unsafe installation of electrical wires in basement. (CBC § 114.1; PAMC § 16.04.225) 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) 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) 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. 122 of 163 PAMC Violation: Improper use of emergency egress access. Propping a door for emergency exit is unsafe. 123 of 163 PAMC Violation: Removal of Fire Doors, creating unsafe conditions. 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) 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) 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) 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) 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) 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) 130 of 163 PAMC Violation: Unsafe penetration in wall. 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) 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) 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 § 16.40.020 134 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 § 16.40.020 135 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 § 16.40.020 136 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) 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). 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) 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)) 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) 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. 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)) 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) 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) 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)) 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) 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) 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)) 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) 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) 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) 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) 153 of 163 PAMC Violation: Improper storage of hazardous materials. 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) 155 of 163 PAMC Violation: Unsafe penetrations in walls located in a mechanical room. 156 of 163 PAMC Violation: Improper materials used for duct venting 157 of 163 PAMC Violation: Improper materials used for fire penetration caulking. 158 of 163 PAMC Violation: Broken door assembly. Many instances of similar conditions located throughout the buildings. 159 of 163 Section IV: 531 Stanford Avenue Postings 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. 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. 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. 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. From:Brian O"Neill To:Council, City; Clerk, City Cc:Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki; Lait, Jonathan; Prior, Christine; Asher Orion Subject:Agenda Item 11 - 531 Stanford Date:Monday, April 20, 2026 12:04:23 PM Attachments:2026.04.20 Appeal Brief.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Council: Please see the attached response to the Staff Report submitted on behalf of the Appellant for Agenda Item 11 on tonight’s agenda regarding the Demolition Order for 531 Stanford. The Exhibits are too large to submit via email, and can be accessed here: https://pattersononeill.egnyte.com/fl/dWtdKVrdhVCj Thank you for your attention to this important matter. Sincerely, Brian O’Neill Patterson & O’Neill, PC Office: (415) 907-9110 Direct: (415) 907-7702 235 Montgomery Street, Suite 950 San Francisco, CA 94104 brian@pattersononeill.com www.pattersononeill.com This email may contain privileged or confidential material for the sole use of the intended recipient. Review or distribution by others is strictly prohibited. If you are not the intended recipient, please contact the original sender and delete all copies. Nothing in this email or any attachments should be regarded as tax advice unless expressly stated. 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 Palo Alto City Council Office of the City Clerk: City Hall, 7th Floor 250 Hamilton Ave. Palo Alto, CA 94301 Re: Appeal of Notice and Order to Demolish/Deconstruct and Remove Buildings 531 Stanford Avenue Dear Mayor Veenker and Councilmembers: This letter is to provide additional information in support of the Owners’ appeal of the City Building Official’s Notice and Order to Demolish/Deconstruct and Remove Buildings (“Demolition Order”) for the existing buildings at 531 Stanford Avenue, site of the Stanford Terrace Inn. The existing buildings do not meet the criteria to support a demolition order under City’s Municipal Code, and the City lacks substantial evidence to support ordering the demolition of structurally sound buildings. The Demolition Order also demands deconstruction, which cannot be legal required. Regardless, the Owners are nonetheless already in the process of seeking the approval of a housing development project on the site that would ultimately result in the removal of the buildings and construction of 21+ units of new housing (Planning Application No. 26PLN- 00011). In fact, the Owners have been attempting to pursue redevelopment since 2023 – prior to the City’s first Notice of Violation issued in 2024 – but these efforts have been stymied time and time again. The Demolition Order is yet another example of the City’s attempt to take the Owners’ property without just compensation and prevent any economically beneficial use of a privately owned property. The Owners have promptly responded to all the City’s demands to address any issues with property, including securing the site, addressing violations, removing debris, ensuring hazardous materials were removed, and maintaining landscaping. Rather than prematurely order demolition, the Council should grant the appeal, modify the Demolition Order, and direct City staff to focus on the approval of desperately needed housing that will accomplish the same goal. The Buildings Do Not Meet the Criteria For Demolition The Palo Alto Municipal Code only provides a City Building Official with the authority to order the demolition of a dangerous building in two limited circumstances. Specifically, a City Building Official can only require demolition if 1) a dangerous building is fifty percent damaged, decayed or deteriorated from its replacement value or structure or where a building cannot be repaired so that it will no longer violate the City code; or 2) where a dangerous building is a fire hazard existing or erected in violation of the City Code. (PAMC 16.40.050(c).) The Demolition Order cites this provision but fails to provide any findings to support the Demolition Order. This is unsurprising, because the buildings at 531 Stanford do not meet the requirements that would permit the City to order demolition of a private building. First, the buildings have not sustained damage, decay or deterioration in an amount equal to 50% of their replacement value. The Owners had the buildings inspected by a structural engineer, who confirmed that the buildings are structurally sound and remain in good condition. The City has not provided any assessment of the value, nor documented the cost of repairs, let alone documented that such damage equates to an amount equal to 50% of the replacement value. Courts have found that an arbitrary determination that a building should be demolished rather than repaired is invalid. (Perepletchikoff v. City of Los Angeles (1959) 174 Cal. App. 2d 697.) The City lacks any evidence at all that buildings meet this criteria. Nowhere in the 250+ page staff report, published just days before the hearing, does the City even attempt to place a value on the buildings. The City cannot possibly make findings that the buildings are fifty percent damaged from their replacement value when no value has been identified. Second, the buildings do not pose any fire hazards and were erected in compliance with City Code in effect at the time of construction. The Demolition Order repeats many of the same conclusory findings of purported violations that were issued in a prior Notice of Violation. The complete lack of specificity and evidence in the Demolition Order makes it impossible for the Owners to address with particularity the City’s findings. This itself is an issue of due process, as the City Code requires a Demolition Order to include a “finding that repair or rehabilitation is impracticable, with a brief statement of the facts upon which such finding is based.” (PAMC 16.40.060(b)(2).) Here, the Demolition Order contained no such findings or facts, preventing the Owners from having a meaningful opportunity to respond. Courts have explained that a property owner has an “elementary . . . clear constitutional right” to due process regarding “whether in fact and law” a property is a nuisance that requires demolition. (Leppo v. City of Petaluma (1971) 20 Cal. App. 3d 711) The City has now published a 250+ staff report just days before the hearing, finally elaborating on these purported violations, which demonstrate that many of them are inaccurate, immaterial, or grossly overstated, while many others have already abated by the Owners. Even now after ther 250+ pages have been published, many of the “violations” lack any specificity or evidence, often with no citation to any specific code. A vague statement that a particular issue violates the entirety of the PAMC does not provide the Owner’s with the ability to respond. For example, one of the major claims is that the buildings fire sprinklers have not been inspected and are not functional. This is false. The Owners completed the 5-Year internal sprinkler checks and hydrostatic testing required by Title 19 in 2020, with testing again in 2023, which confirmed that the sprinklers were functional and passed all required tests prior to the 2024 Notice of Violation. (See Exhibit A). While the declarations of City officials state visual observations “indicates” that the sprinklers could fail – actual testing of the system contradicts this claim. The City officials also suggest, without actually stating, that a lack of sprinklers on the upper floors is a code violation. This is unsurprising that the City officials do not state that this is a code violation, because it is not, as the officials are likely quite aware that existing buildings are only required to be equipped with sprinklers for A-2 (assembly for food/beverage) and I-2 uses (buildings for 24-hour medical care of five or more persons). The City also claims various other violations that are simply not true. The City states that the pool was installed without a permit. While installation of the pool long pre-dates the Owner’s involvement with the property, the Owners have pool installation plans provided by the prior owners dating from 1998 that state a permit had been issued. (See Exhibit B.) Other examples include a purported unpermitted gazebo even though detached accessory structures less than 120 square feet are exempt from permit requirements. The City claim the Owners violated City code by referring to the building as 520 Oxford because this address “was never formally assigned,” yet admit that the “property is also referenced in various records as 520 Oxford Avenue.” Other inconsistencies include claiming that the elevators “were not in service,” while earlier claiming the elevators were operating without proper certifications. Other purported violations are simply conjecture without evidence, such as the claim that it “appears” that the second-floor balcony had been shored “indicating awareness” of a structural deficiency. The City uses this “appearance” of work to infer the subjective determination of an unknown third party to come to a “potential” conclusion of a structural deficiency. This, of course, is nonsensical. If the Owners did indeed complete unpermitted shoring work, this work would have fixed any structural issues. The City’s declarations do not state that the balcony is displaying any lagging, splaying, fracturing, or any other visible sign of damage. Furthermore, these posts were installed as landscaping features for climbing vines. As the City is aware, these posts were removed after the City claimed they were unpermitted – without any impact on the second-floor balcony. Many of the cited violations could be easily corrected, such as fixing signage, labeling electric panels, removing pillow and bedding storage, and ensuring that accessways and egress remains clear – and many of these violations were addressed in the immediate aftermath of the first Notice of Violation. Then after the Owners had complied with some of the City’s demands, such as removing lighting and signage, the City then issued a violation for missing signage. Other violations are for purported unpermitted work (which the Owners do not concede are all true) that could be remedied simply with the submittal and approval of a permit. However, as explained, the Owners have been seeking to redevelop the property. It simply does not make sense to pursue approval of permits to legalize any work at this point. But regardless, none of these violations rise to level of ordering structurally sound, privately owned buildings demolished. Finally, some of the violations are merely about habitability and occupancy. The City very well knows that the building was ordered to be vacated. The City has ordered that the buildings be locked, and the Owners themselves do not even have permission to enter their own buildings for over a year. A vacant building cannot possibly be in violation of use and occupancy requirements. The City has failed to make the findings and present facts to require demolition of the buildings because the buildings do not meet the criteria for demolition. As such, the Demolition Order cannot be upheld. At a minimum, the City must provide the findings and facts to the Owners to provide the Owners with a meaningful opportunity to respond. The City Lacks the Authority to Require Deconstruction The Demolition Order cites to PAMC § 5.24 in support of the City’s demand for deconstruction. The City Code requiring deconstruction 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. Even if the City upholds the Demolition Order, the City’s requirements for deconstruction in PAMC § 5.24 clearly would not apply. We are unaware of any other code basis that would authorize the City to require deconstruction and the City’s demand for deconstruction is not authorized by law. The Owners Have Already Submitted and Completed a Hazmat Closure Permit and Submitted a Demolition Permit The Demolition Order demands that the applicant take immediate steps to submit two applications, including a demolition permit and hazardous material closure permit. The Owners first submitted a demolition application in October 2024. The City had this application for over a year and never identified any deficiencies. The City refused to even consider a demolition application until September 2025, first stating that demolition could not be completed until a redevelopment plan was approved. The Owners submitted this application again in October 2025. (See Exhibit C, Declaration of Isaac Winer). In addition, the Owners already submitted a Hazmat Closure Permit (Permit No. 24HZM- 00040). The Hazmat Closure plan was approved by Palo Alto Fire Department, and the Owners completed all steps necessary to complete the plan. The Owners’ representatives did a final walk-through with Mike Espeland of Palo Alto Fire Department in May 2024 to confirm all steps had been completed. (See Exhibit D, Declaration of Isaac Winer). It is unclear why the Demolition Order continues to list violations that have long been abated and demand applications that have already been submitted. This appears to be aimed at creating a false impression that the Owners have been dilatory and negligent in responding to City staff. Nothing could be further from the truth. (See generally Declaration of Isaac Winer.) In fact, as explained in more detail below, the Owners have made multiple attempts to ensure the property is well maintained and provide reasonable investment-backed expectations. The reason why the property is currently fenced off with vacant buildings is solely due to the City’s actions. And not the City has used this vacancy to its advantage, claiming that this has led to deterioration to support its Demolition Order. The City itself has prevented the Owners have from accessing their own property to keep it maintained. The City Has Systematically Taken Steps to Prevent Any Use of the Property History of Non-Transient Residential Use The current Owners 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 operations of the existing Stanford Terrace Inn, a well-known hotel that had operated for decades prior to Fortune’s ownership. The hotel had a long history of hosting many guests for long-term stays, including faculty members and students who used the Stanford Terrace Inn as their residence, as well as short-term transient guests. In 2018, the buildings were sold to Aurora Rising, Inc. (“Aurora”), who continued to operate the Stanford Terrace Inn in the same manner. In the Spring of 2020, as a result of COVID, the Stanford Terrace Inn 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 the non-transient users, specifically Stanford faculty members and students who continued to reside at the property for stays longer than 30 days. On the advice of former counsel, the Owners increased the number of long-term guests upon the belief that this use was not only lawful, but a benefit to the community. Contrary to the staff report’s claims, the Owners continued to register the hotel as a business and kept up with City permit requirements. (See Exhibit E.) On or about June 18, 2021, the City of Palo Alto sent a letter to the ownership of Stanford Terrace Inn, 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. At this time the Owners informed the City that they were in discussions with a hotel operator to renovate the property into a four-star, high-end hotel. In other words, just four years ago the City believed the Stanford Terrace Inn was not only suitable for residential uses, but desired to purchase the buildings that it now seeks to order demolished. The City Prevents Continued Historical Use of the Property On February 28, 2024, the City sent a “courtesy notice” of the City’s intention to inspect the buildings for an enforcement “investigation” based on a determination that the property appeared to be used for long term stays – even though the Stanford Terrace Inn had long been used for such purposes and the City had been aware of this well-established use for years. The City took the position that because the number of transient guests had dwindled, the hotel use had been abandoned. Because the property was zoned RM-30, the City made clear that its preference was for the property to be redeveloped for high density housing. The Owners believe this particular property had been singled out by the City for disparate treatment. While many other hotels in the City also regularly allow long term stays, the Owners know of no other investigations or similar actions being taken against other properties. The City Prevents Any Continued Use of the Property Three days after the Planning Department met with the property management’s legal representative to discuss redevelopment options now that the City took the position that the hotel use had been abandoned, the City issued a formal Notice of Violation. The City then embarked on an aggressive enforcement campaign, sending more than ten officials to investigate the property, including code enforcement, building, and fire officials. Many officials arrived in uniform with badges, conducted an aggressive and comprehensive search, and photographed and documented technical code violations throughout the premises. The Notice of Violation cited numerous purported violations without citing to any specific code provisions. Some of the violations were related to residential code standards that would only apply if the hotel had been abandoned. The Notice required immediate fire-watch services by March 22, complete evacuation of upper floors, and numerous corrective actions by March 25, 2024. The Notice also warned of possible declarations of substandard conditions, fines, or abatement orders if compliance was not achieved. The Owners complied, including by providing fire watch services and taking remedial actions such as providing smoke detectors and carbon monoxide alarms, removing deadbolts from doors, and ensuring all exits were cleared. Ultimately, ownership was forced by the City to cease long term guest stays and clear the building. The City Strips the Owners of Builder’s Remedy Vesting Rights Following the Notice of Violation, Owners sought to redevelop the property for high-density housing. The Owners submitted a preliminary application for 36 units of new housing, including six below-market-rate units, utilizing the “builder’s remedy” provision of the Housing Accountability Act on April 10, 2024. (Application No. 24APP-01150.) The Owners submitted a formal application on September 16, 2024 – within 180 days of the preliminary application submittal to maintain vesting rights in the builder’s remedy. City staff, however, took the position that the formal application would not be considered “submitted” until the applicant scheduled an intake appointment, the City’s system issued an invoice, and application fees were paid. The City denied payment and unlawfully removed the application from the City’s system. The Department of Housing and Community Development, the state agency tasked with enforcing state housing law, has advised local governments that fee invoices must be provided concurrently with submittal and any delay in providing fee invoices is inconsistent with the Permit Streamlining Act.1 HCD has also confirmed that requiring “intake” meetings before an application is considered “submitted” is inconsistent with the requirements of the Permit Streamlining Act and a constraint on the development of housing.2 Because the City unlawfully prevented the Owners from submitting a formal application and the City had subsequently come into compliance with the Housing Element Law, the Owners lost the ability to pursue the builder’s remedy project. (See Exhibit F.) But this is not the only application that the Owners submitted. The Owners submitted multiple different plans for projects of various sizes over several months. Each time an application was submitted, it was removed from the City’s system or otherwise blocked by City staff. (See Exhibit G.) To suggest that the Owners have done nothing over the 18 months is simply not true. The Owners have consistently attempted to pursue demolition and redevelopment over the last three years without success. The Owners Are Pursing a New Housing Project and the City Continues to Delay The Owners have since filed a new preliminary application for a 21-unit housing project on August 19, 2025. (Application No. 25PLN-00209). Our office submitted the preliminary application with a request that the City issue a CEQA exemption consistent with the newly enacted AB 130 exemption. The City appeared to cooperate and began AB 130’s tribal consultation process. The owner’s representative met with City officials on September 11, 2025. The parties all seemed aligned to cooperate moving forward, keep open dialogue, and move toward the goal of demolishing the existing building and redeveloping the property. (See Declaration of Isaac Winer.) Several months went by and our office requested issuance of the CEQA exemption on December 4, 2025. The City responded by arguing the Project did not qualify for the exemption and that the 1 See HCD’s Letter of Technical Assistance to Los Gatos, available here: https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/HAU/losgatos-hau891- ta-08302024.pdf 2 See HCD’s Letter of Technical Assistance to the City of Berkeley, available here: https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/HAU/berkeley-ta- hau331-120723.pdf City had conducted the tribal scoping “in error.” While we disagree, it is inexplicable why this was never communicated to the Owners. The City simply made this determination in secret and waited for three months for Owner’s attorney to follow-up. (See Exhibit H.) Further, while delaying approval of the Project, the City unilaterally sent the Demolition Order (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. And this was merely a few weeks after meeting face to face to discuss cooperation and open communication. The formal application was subsequently submitted on January 16, 2026 and the Owners have continued to pursue the current iteration of the project, yet the City has continued to stonewall the application most recently by issuing Notice of Incompleteness/Corrections that fails to comply with state law. Further, the Owners have been unable to focus its efforts on the planning process while having a looming Demolition Order an appeal clouding the property. The City’s Actions Demonstrate a Pattern of Regulatory Overreach and Arbitrary Action that Prevents Beneficial Use of the Owners’ Property The City’s actions described above have cost the Owners enormously both financially and emotionally. 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 has provoked a systematic campaign of retaliation to prevent any beneficial economic use of their private property – first wrongfully finding that a historical nonconforming use had been abandoned; pursuing an aggressive and heavy-handed enforcement action; unlawfully preventing a housing project aligned with the Owners’ goal; and finally resulting in a Demolition Order that lacks the required findings and evidence. The City has insisted on treating the removal of the current buildings separately from the proposed project, demanding that the Owners agree to a demolition timeline without providing any assurances that the Project will be timely approved. This is unacceptable. First, separating demolition from the redevelopment of the property will significantly increase construction costs and impact the financial feasibility of the Project. This would require removing the buildings, securing grading permits, backfilling the site, and removing all construction equipment – only to begin construction again in the near future and excavate the site that was just filled. This demand to demolish first is simply another attempt to prevent any redevelopment. Second, there is an existing T-Mobile tower on the hotel building that needs to be relocated, and the proposed redevelopment is necessary to ensure uninterrupted service. Owners believe that this T-Mobile tower is critical to ensure adequate service for the City, including for emergency personnel. Third, the Owners are concerned that a vacant property with no active use will be a magnet for nuisance activities, trespassing, and other activities that will create a liability. The Demolition Order will Appeal Request Despite these prior challenges, the Owners have continued to engage in discussions with City personnel in an effort to redevelop the property – a goal shared by the Owners, the City, and the Community. The Demolition Order is not only legally deficient, it hinders that shared goal and does not demonstrate that the City is operating in good faith toward an amicable resolution. The Owners would have no reason to trust that the City will process the current pending application and may have no choice but to seek legal action to protect their property rights. This is not an outcome that any party desires. As explained above, the Owners have been proactive in responding to the City’s concerns and are diligently pursuing a pending housing development project application that would result in removal of the buildings. While the buildings do not meet the criteria for demolition, the Owners only object to the unreasonable timeframe to complete the demolition and the “decoupling” of the demolition from the approval of the pending application and relocation of the T-Mobile tower. Based on the City’s prior actions, the Owners have grave concerns that the City will continue to stonewall the Owner’s desired redevelopment plans. Pursuant to City Code, the Council has the authority to affirm, reverse, modify or set aside any order or action of the building official. (PAMC § 16.40.080(e).) To that end, Owners request that the Council modify the building official’s order to require demolition only upon the approval of Application No. 25PLN-00209 and associated building and demolition permits. Very truly yours, PATTERSON & O’NEILL, PC _______________________________ Brian O’Neill From:Rosita Wong To:Council, City Subject:Public comment for item 11 on Council Meeting April 20 agenda Date:Monday, April 13, 2026 1:21:29 PM Attachments:Council Meeting April 20 Public Comment item 11 - WONG.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear City Council, Please kindly find attached my public comment for item 11 on the council meeting agenda on April 20. Thank you, Rosita Wong 546 Oxford Ave Palo Alto From:Rosita Wong To:Council, City Subject:One change - Public comment for item 11 on Council Meeting April 20 agenda Re: Your e-mail to City Council was received Date:Monday, April 13, 2026 1:31:29 PM Attachments:Council Meeting April 20 Public Comment item 11 - WONG.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i This message needs your attention This is a personal email address. Mark Safe Report Dear City Council, I had a typo in my public comment. If you can kindly replace the old one with this attached PDF, I will greatly appreciate it. Thank you Rosita On Apr 13, 2026, at 1:21 PM, Council, City <city.council@paloalto.gov> wrote: Thank you for your comments to the City Council. Your e‐mail will be forwarded to all seven Council Members and a printout of your correspondence will also be included in the next available Council packet. If your comments are about an item that is already scheduled for a City Council agenda, you can call (650) 329‐2571 to confirm that the item is still on the agenda for the next meeting. If your letter mentions a specific complaint or a request for service, we'll either reply with an explanation or else send it on to the appropriate department for clarification. We appreciate hearing from you. ------------------Cybersecurity safety note: Official emails from the City of Palo Alto typically end with@cityofpaloalto.org and there are limited exceptions such as surveys or polls that may comefrom City consultants acting on the City’s behalf. Though the City doesn’t often solicit donations,City partners, including local foundations such as the Palo Alto Art Center Foundation, Friends ofthe Palo Alto Library, and Friends of the Palo Alto Junior Museum & Zoo do send out fundraisingcommunications. Please contact the appropriate City department or City Council Member to Powered by Mimecast April 13, 2026 Public Comment to City Council – April 20 Councill Meeting Agenda item 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. Commentor: Rosita Wong, home owner, 546 Oxford Ave (a single family home sharing rear and side property line with 531 Stanford and involved structures) Position: I urge the City Council to uphold the order to demolish the endangered buildings and to proceed with demolition promptly, in full compliance with asbestos and safety regulations. Comments: 1. An endangered complex encircling my house presenting hazards that threaten health and safety The city has fully and professionally examined the structures and, based on evidence, found the complex “to be dangerous and unsafe, constituting public nuisances that pose substantial danger to health, safety, and general welfare”, “The Order was based on findings that the structures were fifty percent or more damaged, decayed, or deteriorated, constituted fire hazards, and could not be repaired to eliminate code violations”.* It has been six months since the Order to Demolish the buildings was issued on October 16, 2025, that my house is standing next to structures facing high-risk of fire hazards due to the buildings’ “dilapidated fire sprinkler and fire alarm systems; high combustible storage creating excessive fire loads; improper hazardous materials storage; severely corroded and exposed electrical wiring creating ignition sources;…non-functioning fire-rated doors and assemblies compromising fire separation”.* My house on Oxford 531 Stanford Structures Any delays to enforce the Order to Demolish pose daily threats to my house and people living inside – physically and mentally. We live with the risk that all it takes is someone leaving an unextinguished cigarette bud inside or around the buildings, especially when the structures are surrounded by uncared weeds, to catch a fire and could burn down the buildings, my house and could cause lives. 2. Increasing unwanted activities in/around 531 Stanford, raising risk of fire and health hazards I had called the police department non-emergency line many times since the buildings were red-taped, reporting individuals: hoping fences to get into the building, camping outside, leaving bottles of urine, food, bedsheets, trash, and even needles. These items are abandoned around the structures, some were left in the sidewalks, and outside my driveway. Oxford and Stanford are the major routes for children to bike to Escondido Elementary, Greene, and Paly. I ended up removing urine bottles, bedsheets, and needles in the mornings to prevent young children coming into contact with these items. I called Public Works many times requesting street cleaning because it smells urination outside the buildings and my house. My ring doorbell recorded an individual walked into my front yard and urinated behind my tree. Rats in the size of a small rabbit are often seen run around outside my house. These unwanted human activities, with cigarette butts, human litters and needles are doubling the risks of fire hazards and threats to public health and safety. These activities are Urine bottle Urine bottle Cigarette butts Cigarette butts unchecked. The police department has no authority to do anything about it. Yet, the vacant buildings continue to attract an increasing level of unwanted activities. One cigarette bud thrown into the buildings with dilapidated fire sprinkler and fire alarm systems; high combustible storage creating excessive fire loads; improper hazardous materials storage would burn down my house and take away lives. I sincerely urge to the city council to take into consideration of threats of the endangered structures to our neighborhood, and to enforce the Order to Demolish immediately without further delay. Being the neighboring property next to 531 Stanford, I am often reminded of the 3-alarm fire on El Camino and San Antonio in December 2023. Despite its separate nature from this case, it highlights the fact that human activities next door, near my doorstep could bring the same fast-spreading fire to my house and to our neighborhood. That grave reminder sent me to countless sleepless nights. 3. Requesting immediate demolition with proper compliance According to public record, 531 Stanford structures were built around 1955. By California law, constructures built prior to 1980 are subjected to asbestos inspection. I know some people close to 531 Stanford have respiratory issues, including myself. I request that any demolition work should meet city and state compliance. The buildings are multi-level and with underground parking, covering four parcels of land. Should there be asbestos contained, the amount of hazardous materials released to the air during months of demolition would be extremely harmful to people living nearby. When I demolished my old property (built in 1952) for re-construction in 2023, I followed the city’s compliance requirement, performed asbestos testing, and removed asbestos found professionally in order to obtain a J permit. 531 Stanford should be expected to follow the same compliance for public safety. 4. Developers’ economic interests should not be prioritized over public safety and human life Our neighborhood has already waited for six months since the Order to Demolish was issued. Each day passes, we risk fire hazards and public health safety threats. I find the developer’s appeal to link the demolition order to its future re-development plan unacceptable and urge the council to consider a rejection to this appeal based solely on the urgent needs for demolition. Residents and homeowners who chose to call Palo Alto home and pay property taxes expect the city to protect our bottom line of safety and properties. That bottom line is universal to all residents and should not be seconded to any developers’ economic calculations. This developer has already set a negative precedent by maneuvering legal procedures to delay (since October 16, 2025) a needed enforcement of code violation that is jeopardizing our safety and quality of life. Most of us in the neighborhood do not have the resources to hire a fleet of attorneys to fight the process. We rely on the city professional staff and the city council members to stand up and defend what is universal to public health and safety for us. Palo Alto is a desirable community for many people because we have one of the most respected planning and building department that enforces high quality of city growth. After evidence-based inspections and repeated examinations by the city supporting a demolition, further delays to a proven, needed enforcement is an attack on our city’s integrity, reputation and the trust that brought us all to Palo Alto. 5. Willingness to work with the developer and the city As the adjacent neighbor to 531 Stanford, I am willing to work with the developer and the city during the demolition work, given that steps taken by the developer follows city’s compliance. Thank you for your consideration. * Information is quoted from city report. From:Rosita Wong To:Council, City Cc:Hana Chandler; michael.julia.grinkrug@gmail.com; Larry Kavinoky; realproduce501@gmail.com; Josie Chang; mel.grondel@gmail.com; lkforrest@yahoo.com; priag@birketthouse.com; sandyflying66@gmail.com; Aileen.lattmann@jll.com; debbie Kaplan; Randy Bluestone; Jiahe (Jan) Wang; TApan Mukerji Subject:April 20 Council meeting - Comments: College Terrace Residents and Merchants comments on 531 Stanford Demolition Date:Monday, April 13, 2026 1:46:54 PM Attachments:Oppose Any Delay of Demolition Enforcement.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i This message needs your attention This is a personal email address. Mark Safe Report Dear Palo Alto City Council Members, We are residents and merchants (all copied in this email) along Oxford Avenue in the College Terrace neighborhood. We respectfully request your support on the following matters concerning 531 Stanford Avenue: Immediate Demolition Enforcement / Do Not Link Enforcement to Redevelopment Approval The structure at 531 Stanford Ave has been determined to be in violation of City code and is currently under enforcement. We urge the City Council to require immediate demolition of the unsafe structure and do not allow the developer to link enforcement to Redevelopment Approval. In addition, demolition must be conducted in full compliance with all applicable safety requirements, including proper asbestos inspection and abatement protocols, to protect the health and well-being of nearby residents, businesses, and families. Thank you for your time, your service, and your commitment to protecting Palo Alto’s neighborhoods and local businesses. Sincerely, College Terrace Residents and Merchants Powered by Mimecast Oppose Any Delay of Demolition Enforcement / Do Not Link Enforcement to Redevelopment Approval (APNs: 137-01-121, 137-01-002, 137-01-003) February 24, 2026 Dear Mayor and City Councilmembers, We are Palo Alto residents and neighbors of the property located on the combined lots APNs: 137-01-121, 137-01-002, and 137-01-003. We are writing to strongly urge the City Council to reject any request to delay demolition enforcement of the decayed structures and to oppose any effort to tie demolition compliance to approval of the developer’s proposed redevelopment plan. The City has already determined that the property is in violation of fire code and poses a hazard to the community. The City Council has previously ruled in favor of demolition. This demolition order is a matter of public safety enforcement, and it must be carried out immediately. The property has remained vacant and deteriorated for an extended period, creating ongoing safety and public health concerns for nearby residents. Vacant and decaying structures have become an attractor for illegal activity, unsanitary conditions, and pests. The City has an obligation to protect the surrounding community from these hazards. Most importantly, I urge the Council to maintain a clear separation between two distinct issues: 1. Code enforcement and demolition of a hazardous property, which is urgent and required for public safety. 2. The proposed redevelopment plan, which is a separate matter that must follow established planning processes, including due process, environmental review (as applicable), and public hearings. Allowing a developer to delay demolition enforcement unless and until a redevelopment proposal is approved would establish a dangerous precedent. It would effectively allow property owners to use public safety compliance as a bargaining tool to gain leverage in the entitlement process. This undermines the City’s enforcement authority and weakens public trust in fair and consistent governance. Additional Concern: Material Misrepresentation of Environmental Safety Standards (PCBs / Hazardous Materials) 1. In addition, the applicant has submitted a signed “PCBs in Priority Building Materials” form (SLLC SB-330 signed.pdf) that appears to be factually incorrect. The applicant certified that the project is exempt from PCB requirements. However, public records and Santa Clara County Assessor data show that the site is a former hotel, not a single-family or duplex residential building, and that the structure was constructed in 1955 and remodeled in 1964. Based on these facts, the correct response to Part 2 Questions A and B should be “YES” to both. Instead, the applicant certified “NO,” which improperly allowed the applicant to bypass mandatory PCB screening and professional sampling requirements required under applicable Regional Water Quality Control Board standards. This is a serious issue. We respectfully request that the City find the application incomplete under Government Code § 65941.1 until a professional PCB sampling report is submitted and reviewed. Further, the certification statement itself warns of significant penalties for submitting false information, which we expect the City to enforce. 2. Additionally, the applicant must comply with the City’s demolition permitting and inspection requirements. Palo Alto requires demolition and construction permit applications to be submitted through the Accela Citizen Access (ACA)portal. For demolitions or significant renovations, inspection for asbestos-containing materials (ACM) is legally required under state and regional regulations (including Cal/OSHA and BAAQMD) before permits are issued or work begins. Given the size of the existing structure, the potential danger of asbestos fibers being released into the air over an extended demolition period—potentially lasting months—poses a serious health risk to nearby residents if proper testing, abatement, containment, and monitoring are not conducted. This is not a minor procedural matter; it is a critical public health protection. Similarly, mandatory PCB screening and professional sampling must not be skipped or omitted, whether intentionally or unintentionally. The City must require full environmental compliance and verification before allowing any demolition or redevelopment activity to proceed. Request to the City Council For these reasons, we respectfully ask the City Council to: • Uphold and enforce immediate demolition of the unsafe structures on these lots; • Reject any proposal that links demolition enforcement to redevelopment approval or delays enforcement as part of negotiation; and • Require full compliance with environmental and hazardous materials requirements, including PCB sampling and asbestos inspection, before any demolition or redevelopment proceeds. Demolition enforcement is a public safety obligation and must not be treated as a bargaining chip. Any redevelopment plan should be reviewed separately and fairly through the normal public process, without shortcuts or political pressure. Thank you for your service and for protecting the health and safety of Palo Alto residents. Sincerely, College Terrace Residents April 20, 2026 www.paloalto.gov Appeal of Order to Demolish 531 Stanford Avenue Presenters: Jonathan Lait, Director George Hoyt, Chief Building Official 2 Purpose of This Hearing The City Council is sitting as a quasi-judicial body to hear an appeal of the Chief Building Official’s Order to Demolish the buildings at 531 Stanford Avenue. Council must consider the administrative record, including •staff reports •expert declarations •photographic evidence Make written findings of fact to support its decision pursuant to PAMC §16.40.080(e). Staff recommend Council deny the appeal and uphold the Order to Demolish. 3 Properly Noticed Hearing Notice of Hearing Pursuant to PAMC §16.40.080(b), the Planning and Development Services Department provided written notice of the time and place of this hearing to the appellant at least seven days prior to the hearing date. Notice was sent on April 9, 2026 by certified mail to the appellant at the address shown on the appeal. This is consistent with the notice requirements of the Palo Alto Municipal Code. Additional courtesy correspondence provided to appellant. City staff have also maintained frequent communication with the property owner representatives and legal counsel throughout the code enforcement process beginning March 2024. 4 Enforcement History The former Stanford Terrace Inn was originally permitted as a hotel. It was converted without permits to residential apartments. This is a change requiring greater life-safety standards than the buildings were designed to meet. •A comprehensive inspection found severe violations: failed fire systems, blocked egress, corroded electrical and plumbing, structural failure requiring emergency shoring, hazardous materials, mold, and extensive unpermitted construction •Despite multiple notices and opportunity to comply, the owner did not remediate the underlying deficiencies; the buildings were red -tagged and vacated •After eighteen months of monitoring with no remediation or rehabilitation performed, the Chief Building Official issued an Order to Demolish •The property owner filed a timely appeal; enforcement of the Order has been stayed pending tonight’s Council decision 5 Conditions Found at Inspection Fire suppression and alarm systems •Dilapidated and non-functional sprinkler and alarm systems throughout all buildings; no testing or maintenance records; corroded sprinkler heads; electrical wiring running in direct contact with sprinkler piping Egress and life safety •Exits blocked throughout; fire-rated doors missing, propped open, or lacking required hardware; no functioning emergency lighting or exit signage; plastic film on ceilings and in exit stairways creating extreme fire propagation risk Structural conditions •Second-floor exit balcony required emergency shoring due to compromised structural integrity; approximately 50% erosion of structural material in basement equipment room ceiling; moisture intrusion and water infiltration throughout 6 Electrical systems •Severely corroded wiring, conduit, panels, and equipment throughout all buildings; open and live junction boxes; extensive unpermitted electrical work; exposed wiring creating ignition risk Mechanical, plumbing, and hazardous materials •Severely corroded piping; unpermitted water heaters, boilers, and storage tanks; pool chemicals, flammable liquids, and liquid propane tanks stored without permits or secondary containment; mold growth and vermin infestation throughout Unauthorized occupancy and unpermitted construction •Buildings permitted as R-1 hotel; operated without authorization as R-2 residential; extensive unpermitted remodeling of all units and all building systems – none permitted, inspected, or approved Conditions Found at Inspection, continued 7 No permits obtained •During the eighteen months from April 2024 through October 2025, no permits were obtained to remediate any identified violation – no structural, electrical, plumbing, fire protection, or occupancy permits of any kind Underlying violations remain unaddressed •No rehabilitation, structural repair, or remediation work performed; the structural, fire safety, and code compliance deficiencies identified at inspection remain entirely unresolved Hazardous materials closure incomplete •Hazmat Closure Permits 24HZM-00040 and 23FDP-00929 are expired Conditions Since Vacation (April 2024 – Present) 8 Conditions continued to deteriorate •Vegetation overgrowth compromised the building envelope; moisture intrusion accelerated system deterioration; all pre-existing conditions worsened significantly during 18 months of vacancy and non-maintenance Security breaches and evidence of unauthorized re -entry •Damage and openings in perimeter fencing; bedding found on exterior walkway consistent with unauthorized occupancy; unauthorized tap into property irrigation line from public water meter; multiple breaches into the interior of the buildings, requiring escalated security measures including the installation of reinforced access panels, and re-securing of all compromised entry points. Conditions Since Vacation (April 2024 – Present) 9 Required Findings To deny the appeal, Council must adopt written findings. Staff recommended findings in Attachment A. Demolition is required when the Building Official (or City Council on appeal) finds any one of the following — PAMC §16.40.050(c): •50% deterioration: A dangerous building fifty percent or more damaged, decayed, or deteriorated from its replacement value must be demolished •Beyond repair: A dangerous building that cannot be repaired to eliminate all violations of this chapter must be demolished •Fire hazard: A dangerous building constituting a fire hazard in violation of this chapter, any City ordinance, or state law must be demolished 10 The Appeal Arguments Objection 1: The Notice and Order was not properly served •The City mailed notice to the property address on county tax records — expressly authorized by PAMC §16.40.060(d). The code is clear that service is effective on the date of mailing regardless of receipt. The appellant’s own timely appeal filing confirms actual notice was received. Objection 2: The buildings do not meet the threshold for demolition •The appellant focuses only on the 50% deterioration criterion, but PAMC §16.40.050(c) provides three independent grounds – any one of which is sufficient. The buildings satisfy all three (50% deterioration, beyond repair, fire hazard). Expert declarations from the Chief Building Official and Fire Marshal document the conditions in detail and are supported by over a 150 photographs in the record. 11 The Appeal Arguments, continued Objection 3: Deconstruction should not be required •PAMC §5.24.080(a)(3) exempts dangerous buildings from deconstruction requirements. The resolution reflects that deconstruction is voluntary. Importantly, this does not affect the underlying demolition order, the exemption addresses method, not the obligation to remove the structures. Objection 4: The compliance timeline is unreasonable •Six months from Council’s decision is standard industry practice for low -rise demolition and provides ample time to schedule work outside wet season. Concerns about T-Mobile equipment relocation and post-demolition use do not justify delaying abatement of an active public safety hazard. These processes can proceed in parallel. 12 Staff 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 at 531 Stanford Avenue, based on the findings and conditions set forth in Attachment A. Conditions of Approval •Demolition permit application filed within 30 days of Council’s decision •All structures, including subterranean garage and swimming pool, completely removed and site secured no later than October 20, 2026 •Subterranean excavations filled with approved materials and graded level •Six-foot perimeter fence with integrated screening installed and maintained •Site maintained clean, safe, and secure at all times – free of debris, overgrown vegetation, and standing water Jonathan Lait Director of Planning and Development Services jonathan.lait@paloalto.gov (650) 329-2679