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
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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:
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(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.
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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
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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.
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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.
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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.
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• 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.
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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;
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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,
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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
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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: _______________________________
_____________________________________________
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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
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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
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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
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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.
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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
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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