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Home My WebLink AboutStaff Report 2603-6103CITY OF PALO ALTO CITY COUNCIL Special Meeting Monday, May 18, 2026 Council Chambers & Hybrid 5:30 PM Agenda Item 12.PUBLIC HEARING / QUASI-JUDICIAL. 4103 Old Trace Road [25PLN-00298]: Request for Approval of a Tentative Map to Allow for the Subdivision of a Vacant 1.02-Acre Lot to Create Nine Residential Lots and One Private Street to Facilitate Construction of Nine New Single-Family Residences and Seven Junior Accessory Dwelling Units (25PLN- 00296). CEQA Status: Exempt Pursuant to Assembly Bill 130 (Public Resources Code Section 21080.66). Zone District: RE (Residential Estate) Supplemental Report added, Public Comment, Staff Presentation, Applicant Presentation CITY COUNCIL Staff Report From: City Manager Report Type: CONSENT CALENDAR Lead Department: Planning and Development Services Meeting Date: May 18, 2026 Report #: 2603-6103 TITLE PUBLIC HEARING / QUASI-JUDICIAL. 4103 Old Trace Road [25PLN-00298]: Request for Approval of a Tentative Map to Allow for the Subdivision of a Vacant 1.02-Acre Lot to Create Nine Residential Lots and One Private Street to Facilitate Construction of Nine New Single-Family Residences and Seven Junior Accessory Dwelling Units (25PLN-00296). CEQA Status: Exempt Pursuant to Assembly Bill 130 (Public Resources Code Section 21080.66). Zone District: RE (Residential Estate) RECOMMENDATION Staff recommends that Council take all of the following actions: 1. Consider the project exempt from the California Environmental Quality Act (CEQA) in accordance with Assembly Bill 130 (Public Resources Code section 21080.66); and, 2. Approve the Tentative Map application pursuant to findings and subject to conditions of approval set forth in Attachment B. EXECUTIVE SUMMARY The applicant requests approval of a Tentative Map to allow the subdivision of a vacant 1.02- acre parcel into nine (9) residential lots served by a new private street located at 4103 Old Trace Road. Through a separate, Streamlined Housing Development Review (SHDR) application, the applicant proposes to construct five detached single-family residences with Junior Accessory Dwelling Units (JADUs), two attached single-family residences with JADUs, and two attached single-family residences (without any accessory units) for a total of 16 units. The attached single-family residence on Lot 9 is proposed at below market rate, made affordable to moderate income households earning no more than 100% of the Area Median Income (AMI). The project is exempt from CEQA pursuant to Assembly Bill (AB) 130 for Qualifying Infill Housing Projects and is proposed in accordance with State Density Bonus Law. BACKGROUND Tentative Map and Final Map for lot subdivision purposes: The process for evaluating this type of application is set forth in Title 21 of the Palo Alto Municipal Code (PAMC) and California Government Code 66452. The process for approval of a Tentative Map for a lot subdivision is outlined in PAMC Section 21.12.090. Tentative maps require Planning and Transportation Commission (PTC) review. The PTC reviews and makes a recommendation on whether the proposed subdivision is consistent with the Subdivision Map Act (Government Code 66474), Title 21 of the PAMC, the Palo Alto Comprehensive Plan, and other applicable provisions of the PAMC and State law. The PTC’s recommendation is forwarded to the City Council for final approval. Housing Accountability Act (Government Code 65589.5): The project constitutes a “housing development project” under the Housing Accountability Act. The Housing Accountability Act Section 65589.5(j) requires that when a proposed housing development project complies with applicable, objective general plan and zoning standards, a local agency may only deny or reduce the density the project or reduce its density if the agency first finds that, (1) the development would have a specific adverse impact on public health or safety unless disapproved, or approved at a lower density; and (2) there is no feasible method to satisfactorily mitigate or avoid the specific adverse impact, other than the disapproval, or approval at a lower density. For purposes of the Housing Accountability Act, the receipt of a density bonus, incentive, concession, waiver, or reduction of development standards shall not constitute a valid basis on which to find a proposed housing development project is inconsistent with objective standards. State Density Bonus Law (Government Code Section 65915): State density bonus law defines “base density” to mean the greatest density permitted in either the zoning code or general plan land use designation, including the top of the range, when a range of densities is provided. In addition, when an applicant agrees to provide a specified percentage of units at affordable prices/rents, the applicant is entitled to unlimited waivers of development standards that physically preclude the project and a number of concessions/incentives that result in actual and identifiable cost reductions. Senate Bill (SB) 330 (Government Code Section 65943): California SB 330 (Housing Crisis Act of 2019) allows applicants to freeze local standards at the time a compliant pre- application is submitted and limits the number of public hearings of housing projects to five hearings. SB 330 requires a formal submittal to be provided within 180 days of filing the pre-application. State ADU Law (California Government Code Sections 66314-66331): This State code establishes a statewide baseline for how cities and counties in California may regulate ADUs by local ordinance and what ADUs/JADUs must be approved regardless of conflicting local regulations. It authorizes ADUs on lots zoned for single-family or multi- family residential use with an existing or proposed dwelling; permits separate rental while generally prohibiting separate sales of ADUs/JADUs except where ADU sales provisions apply; and sets size limits for detached and attached ADUs and JADUs. It also restricts conditioning approval on correcting unrelated nonconformities, limits sprinkler triggers and requires rentals for a period greater than 30 days (i.e., restricts short-term rentals). State law requires that proposals to construct ADUs/JADUs be considered ministerially; even when an ADU/JADU is proposed as part of a larger project subject to discretionary review, the ADU/JADU must be considered separately and ministerially after the discretionary review is complete. A separate SHDR application is proposed. The process for evaluating this type of application is set forth in PAMC Section 18.77.073. SHDR applications require a study session with the Architectural Review Board (ARB) and recommendations are forwarded to the Planning & Development Services Director for action following the review. Action by the Director is appealable to the City Council if filed within 14 days of the decision. Pursuant to PAMC Section 18.40.170, the Director may also defer to a final decision to City Council. Streamlined Housing projects are evaluated against specific findings. Both of the findings must be made in the affirmative to approve the project. Failure to make any one finding requires project re-design or denial. Neighborhood Setting and Character The project is located on Old Trace Road in the Esther Clark Park neighborhood and is surrounded on the east, west, and south by single-family residences within the Residential Estate (RE) zone district. To the north of the property is a research facility and office within the Research Park zone district. Surrounding development is primarily two-story. The site is located near research facilities to the west and four public schools within one mile distance to the east. ANALYSIS Ensure that condition #4 requires deed restriction for a BMR unit; Consider allowing public participation in street naming as described in condition of approval #6; Ensure Conditions #8, and 41-48 include all transportation improvements; Ensure Conditions #50 and 51 are consistent with Public Works recommendations; Include a requirement for a Construction Management Plan for the construction of future housing; Consider future investigation and development of fire safety standards to protect against impacts on adjacent neighbors; Consider future update to parking requirements for guests and ADUs; Consider other regulations to address cumulative/compounding impacts on neighbors; and Consider reduction in maximum density allowed for this area under the Comprehensive Plan. allow residents of the new development to make left turns onto Arastradero Road. Instead, westbound traffic would be required to exit onto Arastradero Road and continue to the next location where a U-turn is permitted; however, U-turns are not allowed at the Foothill Expressway intersection. Summary of Response to PTC Comments 1 2 consistent with the proposed density prior to density bonus and JADUs. 1 The Palo Alto Comprehensive Plan is available online: http://bit.ly/PACompPlan2030 2 “Base density” means the greatest number of units allowed under the zoning ordinance, or land use element of the general plan, or, if a range of density is permitted, means the highest density in that range. In addition, all 5The proposed map facilitates development of a vacant parcel within the City’s urban service area which is consistent with Policy L-1.3 wherein, “infill development shall be compatible with its surroundings and the overall scale and character of the city.” Moreover, the proposed project complies with Housing Element Policy 3.2 to, “provide adequate sites, zoned at appropriate densities and development standards to facilitate both affordable and market-rate housing production.” The findings for approval of the subdivision map in Attachment B include a complete analysis of the project’s consistency with the relevant Comprehensive Plan policies. Zoning Consistency6 The site is zoned RE (Residential Estate). The project includes single-family use of each resulting lot, which is a permitted use within the RE zone district. As allowed pursuant to ADU law, JADUs are proposed on seven of the nine resulting lots as accessory uses to the primary dwelling units. These units do not count toward maximum density and may be constructed in accordance with the provisions pursuant to ADU law under California Government Code Sections 66314 through 66331 and the City’s ADU regulations as set forth in PAMC Chapter 18.09. Attachment C includes a summary of the Tentative Map’s consistency with zoning development standards, including the base RE zoning standards, as they relate to the lots to be created. Pursuant to State Density Bonus Law, the City must grant any number of development waivers needed to avoid standards that would physically preclude the project at the allowed density. Under State Density Bonus Law, the City may request reasonable documentation to confirm eligibility but may not require a new study or report. The City bears the burden of identifying a valid basis to deny a concession or waiver. For concessions, the City may request documentation showing that the requested concession results in a cost reduction. For waivers, the City may request documentation explaining how the standard would otherwise physically prevent construction at the proposed density. The application includes the following waiver requests related to the approval of the Tentative Map:7 1.Lot Size: Reduce the minimum lot size as set forth in the RE zone and Title 21 from one acre (PAMC Section 18.10.040(a), Table 2) and 6,000 square feet (PAMC Section 21.20.100), to allow for proposed lots to range in size from 1,570 square feet to 6,907 square feet. 2.Setback: Reduce the special setback on Arastradero Road from 53 feet to: 9 feet, 6 inches, on Lot 5; and calculations under State Density Bonus law are rounded up to the next whole number. The Comprehensive Plan Land Use designation allows up to seven units per acre; 7 du/ac * 1.02 ac = 7.14 du, which is rounded up to 8 units. 6 The Palo Alto Zoning Code is available online: https://bit.ly/PAZoningCode 7 Additional waivers are required for the SHDR application and are detailed in Attachment F. 15 feet on Lots 6 and 9. 3.Street width: Reduce the minimum width of the private street from 32 feet (PAMC Section 21.20.024 (b)(4)) to 20 feet. 4.Site depth: Reduce the minimum site depth from 100 feet (PAMC Section 18.10.040 (a), Table 2) to 59 feet. With respect to the setback on Arastradero Road, staff research indicates that it is possible that at the time this special setback was established, the setback may have been measured from the centerline of the street. Nevertheless, the special setback under the current code provisions is measured from the edge of the drainage easement on Arastradero Road. Therefore, although no setback is proposed for Lots 6 and 9, when measured from the drainage easement, the physical improvements on those properties would be set back 15 feet from Arastradero Road. The applicant’s project description is provided in Attachment F and includes a list of requested waivers and concessions in accordance with State Density Bonus Law and the justification for the requests. As detailed further in this report, if the project is designed to comply with all relevant development regulations, after application of density bons incentives, concessions and waivers, the City cannot impose conditions that would preclude construction of the project as proposed. Multi-Modal Access Vehicular Circulation The project site is currently vacant and has no existing curb cuts. The project proposes a new 20-foot-wide private street to provide access to the residential lots. Although the proposed private street width does not meet the 32-foot minimum required by PAMC Section 21.20.240, the applicant has requested a waiver from this development standard pursuant to State Density Bonus Law. As documented in the traffic study provided in Attachment E, the proposed street width would accommodate the turning movements of passenger vehicles, emergency vehicles, and refuse trucks. Although a single driveway connection from Old Trace Road would be preferable from a pedestrian and bicycle safety perspective (i.e. eliminating the curb cut on Arastradero Road), the proposed through-access configuration would improve on-site circulation and better accommodate emergency vehicles and refuse collection operations. Without the connection to Arastradero Road, refuse service would need to be staged along the Old Trace Road frontage rather than serviced in front of the individual residences/lots. The curbs along the private street would be painted red to designate a fire lane to support fire apparatus and staging and maintain unobstructed access for emergency vehicles. Due to the reduced width of the private street, staff identified a potential conflict point for vehicles turning into the new private street from Arastradero Road. In response to concerns raised by the ARB and public commenters at the March 5, 2026, ARB study session, the applicant revised the map to restrict right-turn movements from Arastradero Road into the new private street. This restriction would be implemented through a reduced curb radius design to physically restrict right-turn movements, in conjunction with proper signage and striping at the west corner of the Arastradero Road entrance. Driveway Configuration and Parking Emergency Vehicle Access It should also be noted that parking within 20 feet of the approach side of any marked or unmarked crosswalk is already prohibited under California's Daylighting Law (Assembly Bill 413, California Vehicle Code 22500(n)), which took effect January 1, 2024, and has been fully enforceable since January 1, 2025. As such, parking within the 20- foot approach is not permitted under state law, regardless of curb markings or signage. The proposed red curb markings will provide clear delineation of this existing legal restriction, ensuring drivers are aware of parking restrictions. The applicant is coordinating with both departments and the project civil engineer regarding installation of red curb markings and/or signage along the Old Trace Road frontage. It is important to note that the existing curb to curb condition on Old Trace Road is 30 feet, with parking allowed on both sides and no sidewalk. The proposed curb-to-curb width would be maintained, with parking now restricted on Old Trace Road between Arastradero and the new private street, and the addition of a sidewalk adjacent the 4103 Old Trace Road property beyond that 30-foot curb-to-curb. Therefore, the project addresses an existing safety condition raised by residents about emergency vehicles access and adds pedestrian improvements, which improve emergency vehicle access in comparison to existing conditions. Bicycle and Pedestrian Improvements Trip Generation lower vehicle ownership and trip generation than primary dwellings. Therefore, the subdivision, which would develop one single-family residence on each resulting lot, is expected to increase net PM peak trips from zero to nine, as detailed in Attachment E. Even using a conservative assumption, the seven JADUs would generate approximately four additional PM peak hour trips, including two inbound and two outbound trips. However, pursuant to SB 54310, impact fees may not be imposed on ADUs of 750 square feet or less or on JADUs since they are always less than 500 square feet. Accordingly, no transportation impact fees would be required for trips attributed to the proposed JADUs, consistent with the conclusions derived in Attachment E. FISCAL/RESOURCE IMPACT 11 The project would be required to pay Development Impact Fees, currently estimated at $931,404.74, in addition to the applicable public art fee. Further, pursuant to PAMC Section 16.65.030(c), a housing in-lieu fee, currently estimated at $588,316.67, would be required for the fractional affordable housing unit. The parkland dedication fee must be paid prior to Final Map approval. All other fees associated with the streamlined development application would be due prior to issuance of building permits. Fees may be deferred to occupancy in accordance with PAMC Section 16.65.030(c) and State law. STAKEHOLDER ENGAGEMENT Lack of bicycle and pedestrian infrastructure along Old Trace Road. Congestion and queuing along the Old Trace Road and Arastradero Road intersection. Limited ingress and egress to and from Old Trace Road onto Arastradero Road with added traffic impact from the proposed development. Emergency services access. Potential construction impacts. 10 SB 543 Bill Text: Bill Text - SB-543 Accessory dwelling units and junior accessory dwelling units. 11 Link to 2026 Municipal Fee Schedule: Adopted Municipal Fee Schedule.book Several members of the public who attended the ARB Study Session were also present at the PTC hearing on April 29, 2026, and reiterated their concerns on the aforementioned topics. One concern raised at the PTC hearing was regarding the potential impacts on homeowners’ insurance as a result of the new development, a concern which was also voiced by several Commissioners. While staff cannot speak to the experience of individual public commenters, staff did reach out to an insurance agent for more insight into this statement and were informed that the proposed development should not have an impact on the availability of insurance on neighboring properties. The public also requested to stay involved in the naming of the private street which per City of Palo Alto Resolution 5739 requires a recommendation from the Palo Alto Historical Association (PAHA) and approval by Council prior to recordation of Final Map. Historically, PAHA has considered any names put forth by neighbors or developers. However, in accordance with this resolution, PAHA selects and recommends a name for the street based on historical research of the area. Therefore, staff will convey any naming suggestions from the neighbors to PAHA, but no changes have been made to the City’s standard condition of approval. ENVIRONMENTAL REVIEW On February 4, 2026, following the applicant’s submittal of additional information and revised plans, the City determined that the project meets the definitions of “urbanized area” and “infill site” under the PRC sections referenced above and is exempt from CEQA pursuant to AB 130. Accordingly, the City sent notification letters inviting tribes to participate in consultation on the project. ATTACHMENTS APPROVED BY: 53 224.8' 214.5' 149.7' 31.5' 18.1' 206.6' 244.4' 160.0' 336.5' 244.4' 300.1' 27.0' 111.7' 300.1' 01.3' 30.8' 230.0' 31.4' 27.0' 31.4' 250.0' 224.8' 122.0' 484.3' 6.1' 120.0' 10.0' 120.0' 845 4103 4111 4110 845A OLD TRAC E ROAD ARASTRADERO ROAD N E This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend Project Site Current Features 0'48' Project Location Map: 4103 Old Trace Road CITYOF PALOALTO I NC O R P O R A TED CALIFORNIA P a l o A l t o T h e C i t y o f APRIL 1 6 1894 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Alto nkandik, 2026-02-04 10:48:50 Attachment A. Location Map (\\cc-maps\Encompass\Admin\Personal\Planning.mdb) 1 1 0 4 0 1 DRAFT ACTION NO. 2026-__ At its meeting on ____________, the City Council of the City of Palo Alto (“City Council”) _____________the Tentative Map to subdivide a vacant lot into nine residential lots, making the following findings, determinations and declarations: SECTION 1. Background. A. On November 7, 2025, Steel Bridge Homes Palo Alto submitted a subdivision map application for a Tentative Map to subdivide a vacant lot into nine residential lots at 4103 Old Trace Road (“The Project”). The project site is a vacant 1.02-acre lot situated at the intersection of Arastradero Road and Old Trace Road (APN 175-20-078). Adjacent uses include a mix of one- and two-story single- family residences to the east, west and south and a research facility to the north. B. Following staff review, the Planning and Transportation Commission reviewed the project and recommended unanimous approval on April 29, 2026, subject to conditions of approval. C. On _____________2026, the City Council held a public hearing in accordance with the City Council’s policies and procedures and __________the project subject to conditions of approval. SECTION 2. Environmental Review. The City, as the lead agency for the Project, has determined the project is exempt from California Environmental Quality Act (CEQA) in accordance with AB 130 [Public Resources Code section 21080.66]. Documentation to support the streamlined review is available as part of the public record on file with the Planning and Development Services Division. SECTION 3. Tentative Map Findings. A legislative body of a city shall deny approval of a Subdivision Map, if it makes any of the following findings (California Government Code Section 66474). The City Council cannot make these findings for the following reasons: 2 1 0 4 0 1 1.That the proposed map is not consistent with applicable general and specific plans as specified in Section 65451: There is no adopted specific plan for this project site. The site is consistent with the Comprehensive Plan as described below. 2.That the design or improvement of the proposed subdivision is not consistent with applicable general and specific plans: There is no adopted specific plan for this project site. The proposed Tentative Map and related improvements are consistent with the Comprehensive Plan in that it facilitates housing development on a site designated for single-family use within the urban services area, consistent with Policy L-1.3 of the Land Use Element and Policy 3.2 of the Housing Element. The proposed density is consistent with the range of densities provided in the Land Use Element, as modified by State Density Bonus law. The Project includes nine residential lots, each with a single-family residence; seven of the nine residences include Junior Accessory Dwelling Units (JADUs). One of the single-family residences is provided at a rate affordable to moderate- income households earning no more than 100% of the Area Median Income (AMI). The Project proposes in-fill development and contributes to the housing inventory. 3. That the site is not physically suitable for the type of development: The Project site is suitable for single-family residential development in that the Comprehensive Plan land use designation of “Single Family Residential allows for detached single-family residential neighborhoods with net densities ranging from 1-7 units per acre and can increase up to 14 units per acre on parcel that include a second unit or duplex. The proposed number of single-family units created on the resulting parcels complies with the applicable densities set forth in the land use element and zoning code. In addition, the Project is proposed pursuant to the State Density Bonus Law and Housing Accountability Act (Government Code section 65589.5) and is consistent with the standards set forth therein. 4.That the site is not physically suitable for the proposed density of development: The proposed project consists of one single-family residence on each of the nine resulting lots, which is permitted use within the Residential Estate (RE) zoning district. In addition, Junior Accessory Dwelling Units (JADUs) are proposed on seven of the nine lots. Pursuant to State ADU law, the JADUs are considered accessory to the primary dwelling units and are not counted toward the maximum allowable residential density. The base density for the site is calculated at 7 dwelling units on a 1.02-acre lot, resulting in a fractional density of 7.14, rounded up to 8 dwelling units per acre pursuant to Palo Alto Municipal Code (PAMC) Section 18.15.020(u). The applicant proposes a total of 9 dwelling units, including one affordable unit, and is therefore entitled to a 7% density bonus pursuant to State Density Bonus Law. Accordingly, the proposed 3 1 0 4 0 1 density of 9 dwelling units per acre is consistent with the density permitted under State Density Bonus Law. 5. That the design of the subdivision or the proposed improvements are likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat: 6. That the design of the subdivision or type of improvements is likely to cause serious public health problems: 7. That the design of the subdivision or the type of improvements will conflict with easements, acquired by the public at large, for access through or use of, property within the proposed subdivision. In this connection, the governing body may approve a map if it finds that alternate easements, for access or for use, will be provided, and that these will be substantially equivalent to ones previously acquired by the public. This subsection 4 1 0 4 0 1 shall apply only to easements of record or to easements established by judgment of a court of competent jurisdiction and no authority is hereby granted to a legislative body to determine that the public at large has acquired easements for access through or use of property within the proposed subdivision. There are no public access easements over the property currently. Therefore, the design of the subdivision will not conflict with any public easements for access through, or use of, the property. New public utility easements will be provided to existing and proposed electrical utilities as part of this subdivision map as required in accordance with City of Palo Alto Utilities standards. A new 20-foot private street will be provided to provide access to the proposed residential lots, including an additional 10 feet width along Lots 6, 7 and 8 to provide a 4-foot wide sidewalk, consistent with project plans. SECTION 4. Tentative Map Approval Granted. Tentative Map Approval is filed and processed in accordance to PAMC Section 21.12.090 and granted by the City Council under PAMC Sections 21.12 and 21.20 and the California Government Code Section 66452, subject to the conditions of approval in Section 6 of this Record of Land Use Action. SECTION 5. Final Map. The Final Map submitted for review and approval by the City Council shall be in substantial conformance with the Tentative Map prepared by Steel Bridge Homes titled “THE OAKS SUBDIVISION TENTATIVE SUBDIVISION MAP” consisting of eleven pages, dated and submitted May 5, 2026, except as modified to incorporate the conditions of approval in Section 6. A copy of the Tentative Map is on file in the Department of Planning and Development Services, Current Planning Division. Prior to the expiration of the Tentative Map approval, the subdivider shall cause the subdivision or any part thereof to be surveyed, and a Final Map, as specified in Chapter 21.08, to be prepared in conformance with the Tentative Map as conditionally approved, and in compliance with the provisions of the Subdivision Map Act and PAMC Title 21 and submitted to the City Engineer (PAMC Section 21.16.010[a]). SECTION 6. Conditions of Approval. Planning 1. PROJECT PLANS. The Final Map submitted for review and approval by the City Council shall be in substantial conformance with the Tentative Map titled “THE OAKS SUBDIVISION TENTATIVE SUBDIVISION MAP”, prepared by Steel Bridge Homes and submitted May 5, 2026, except as modified to incorporate the conditions of this approval. 2. FINAL MAP COVER PAGE. At such time as the Final Map is filed, the cover page shall include the name and title of the Director of Planning and Development Services. 3. DEVELOPMENT IMPACT FEES. The Property Owner or their designee shall pay all applicable development impact fees associated with the proposed development and 5 1 0 4 0 1 subdivision prior to issuance of the building permit(s) or recordation of the Final Map. Impact fees may be paid prior to occupancy in accordance with the requirements under PAMC 16.64.030 and as permitted by Sb 937. 6 1 0 4 0 1 following multimodal transportation improvements as currently reflected in the Tentative Map: Prior to any on-site grading work, the project applicant shall be required to submit evidence that a Cultural Awareness Training program has been provided to construction personnel. The training shall be facilitated by a qualified archaeologist in collaboration with a Native American representative registered with the Native American Heritage Commission for the City of Palo Alto and that is traditionally and culturally affiliated with the geographic area as described in Public Resources Code Section 21080.3. 7 1 0 4 0 1 11. EVALUATION. The project applicant shall notify the Director of Planning, Native American Monitor, and Archeological Monitor, of any finds during grading or other construction activities. Any historic or prehistoric material identified in the project area during excavation activities shall be evaluated for eligibility for listing in the California Register of Historic Resources as determined by the California Office of Historic Preservation. Data recovery methods may include, but are not limited to, backhoe trenching, shovel test, hand augering, and hand-excavation. The techniques used for data recovery shall follow the protocols identified in the approved treatment plan. Data recovery shall include excavation and exposure of features, field documentation, and recordation. All documentation and recordation shall be submitted to the Northwest Information Center, and the Director of Planning. The qualified archaeologist shall be responsible for submitting all required reports and documentation to the appropriate California Historical Resources Information System (CHRIS) Information Center. 12. TREATMENT PLAN. In the event that any significant cultural materials are encountered during construction, construction within a radius of 100 feet of the find would be halted, the Director of Planning shall be notified, and the on-site qualified archaeologist shall examine the find and make appropriate recommendations regarding the significance of the find and the appropriate treatment of the resource. The qualified archeologist in collaboration with a Native American monitor, registered with the Native American Heritage Commission for the City of Palo Alto and that is traditionally and culturally affiliated with the geographic area as described in Public Resources Code Section 21080.3, shall prepare and implement a treatment plan that reflects permit-level detail pertaining to depths and locations of excavation activities. The treatment plan shall contain, at a minimum: Identification of the scope of work and range of subsurface effects (including location map and development plan), including requirements for preliminary field investigations. Description of the environmental setting (past and present) and the historic/prehistoric background of the parcel (potential range of what might be found). Monitoring schedules and individuals. While coordination will occur jointly, the consulting tribe monitors and archaeological staff shall be notified separately of all scheduling, updates, and field activities to ensure clear and direct communication. Development of research questions and goals to be addressed by the investigation (what is significant vs. what is redundant information). Detailed field strategy to record, recover, or avoid the finds and address research goals. Analytical methods. Report structure and outline of document contents. 8 1 0 4 0 1 Disposition of the artifacts. All cultural materials and artifacts recovered during project-related activities shall remain the property of consulting tribe and shall be returned to the Tribe for final disposition, care, and curation in accordance with Tribal protocols. Security approaches or protocols for finds. In the event that a significant quantity of cultural materials is encountered, the consulting tribe shall require the use of a secure, locked Conex box or equivalent storage unit, to be maintained on-site and managed by the consulting tribe monitor. All associated costs for security measures, including procurement and maintenance of the storage unit, shall be the responsibility of the project applicant/developer. Cultural materials shall remain secured on-site under the consulting tribe oversight until the completion of ground- disturbing activities, at which point the consulting tribe shall assume full possession and responsibility for curation. Appendices: all site records, correspondence, and consultation with Native Americans, etc. The treatment plan shall utilize data recovery methods to reduce impacts on subsurface resources. The treatment plan must be reviewed and approved by the Director of Planning, or the Director’s designee prior to implementation of the plan. 13. HUMAN REMAINS. If human remains are found, the State of California Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. In the event of an unanticipated discovery of human remains, the County Coroner must be notified immediately. If the human remains are determined to be of Native American origin, the Coroner will notify the Native American Heritage Commission, which will determine and notify a most likely descendant (MLD). The MLD has 48 hours from being granted site access to make recommendations for the disposition of the remains. If the MLD does not make recommendations within 48 hours, the landowner shall reinter the remains in an area of the property secure from subsequent disturbance. 14. INDEMNITY. To the extent permitted by law, the Applicant shall indemnify and hold harmless the City, its City Council, its officers, employees and agents (the “indemnified parties”) from and against any claim, action, or proceeding brought by a third party against the indemnified parties and the applicant to attack, set aside or void, any permit or approval authorized hereby for the Project, including (without limitation) reimbursing the City for its actual attorneys’ fees and costs incurred in defense of the litigation. The City may, in its sole discretion, elect to defend any such action with attorneys of its own choice. Public Works Engineering 9 1 0 4 0 1 15. PUBLIC WORKS APPLICATIONS, FORMS, AND DOCUMENTS: Applicant shall be advised that most forms, applications, and informational documents related to Public Works Engineering conditions can be found at the following link: https://www. paloalto.gov/Departments/Public-Works/Engineering-Services/Forms-and-Permits 16. OVERVIEW AND GUIDELINES FOR THE REVIEW OF SUBDIVISION PROJECTS. Developer shall familiarize themselves with the guidelines described in the November 2007 revision of the document titled “Overview and Guidelines for the Review of Subdivision Projects”. Particularly Section II (items 5 through 12) and Section V (items A through C). https://www.paloalto.gov/files/assets/public/planning-amp-development-services/file- migration/current-planning/forms-and-guidelines/overview-and-guidelines-for-the- review-of-subdivision-projects.pdf 17. SUBDIVISION IMPROVEMENT AGREEMENT. The applicant shall execute a Subdivision Improvement Agreement and provide improvement securities (Bonds) for all proposed public improvements. THE AGREEMENT SHALL BE EXECUTED PRIOR TO MAP RECORDATION OR ISSUANCE OF ANY PERMITS FOR CONSTRUCTION, ONSITE AND OFFSITE. ADVISORY -- The applicant shall provide a detailed itemized stamped and signed engineer's estimate for all off-site public improvements which will be reviewed to determine the security amount. 18. FINAL MAP. This project is subject to, and contingent upon the approval of a tentative map and recordation of a Final Map. The submittal, approval and recordation of the Map shall be in accordance with the provisions of the California Subdivision Map Act and Palo Alto Municipal Code Title 21 Subdivision requirements. All existing and proposed property lines, easements, dedications shown on the tentative map are subject to City’s technical review and staff approval during the map process prior to issuance of any construction permits. 19. MAP THIRD-PARTY REVIEW. The City contracts with a third-party surveyor that will review and provide approval of the map’s technical correctness as the City Surveyor, as permitted by the Subdivision Map Act. The Public Works Department will forward a Scope & Fee Letter from the third-party surveyor and the applicant will be responsible for payment of the fee’s indicated therein, which is based on the complexity of the map. 20. STREETWORK PERMIT. The applicant shall obtain a Streetwork Permit from the Department of Public Works for all public improvements. 21. UPGRADE OF EXISTING PUBLIC IMPROVEMENTS. As part of the plan review for improvements within the public right-of-way, any existing improvements to be re-used by the project, which are not to current City standards and are not specifically in these project conditions (such as streetlights, utility covers and lids, etc.), shall be upgraded to current City standards as required by the Director of Public Works and the Director of Utilities. 10 1 0 4 0 1 22. MODIFICATIONS TO EXISTING PUBLIC UTILITIES. The Developer is responsible for any changes or modifications to existing utilities, streets, and public infrastructure within or adjacent to the project site. This includes, but is not limited to, the relocation of utility facilities, conduits, or vaults required due to grade changes in the sidewalk area resulting from the development. The utility design as shown in the Tentative Map is not final. The utility design submitted for the development application (25PLN-00296) shall take precedent. 23. DAMAGE TO EXISTING PUBLIC IMPROVEMENTS. The Developer is responsible for repairing any damage to existing public improvements fronting or adjacent to the project site caused by construction, to the satisfaction of the Public Works Department. 24. EXISTING UTILITY ABANDONMENT AND/OR RELOCATION. The Developer is responsible for researching all existing utility lines to ensure there are no conflicts with the project. Any existing utility lines (public or private) or their appurtenances that conflict with the project or do not serve it must be capped, abandoned, removed, relocated, or disposed of to the satisfaction of the City. 25. GRADING AND EXCAVATION PERMIT. A Grading Permit is required per PAMC Chapter 16.28. The permit application and all applicable documents (see Section H of application) shall be submitted to Public Works Engineering. Add the following note: “THIS GRADING PERMIT WILL ONLY AUTHORIZE GENERAL GRADING AND INSTALLATION OF THE STORM DRAIN SYSTEM. OTHER BUILDING AND UTILITY IMPROVEMENTS ARE SHOWN FOR REFERENCE INFORMATION ONLY AND ARE SUBJECT TO SEPARATE BUILDING PERMIT APPROVAL.” The grading design as shown in the Tentative Map is not final. The grading design submitted for the development application (25PLN-00296) shall take precedent. 26. ROUGH GRADING. Provide a Rough Grading Plan for the work proposed as part of the Grading and Excavation Permit application. The Rough Grading Plans shall including the following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over excavation, stockpile area of material, overall earthwork volumes (cut and fill), temporary shoring for any existing facilities, ramps for access, crane locations (if any), tree protection measures, etc. 27. CIVIL ENGINEER CERTIFICATION. Upon completion of the rough grading work and at the final completion of the work, applicant shall provide an as-graded grading plan prepared by the civil engineer that includes original ground surface elevations, as-graded ground surface elevations, lot drainage patterns and locations and elevations of all surface and subsurface drainage facilities. The civil engineer shall certify that the work was done in accordance with the final approved grading plan. 28. DIRECT CONNECTIONS TO STORM DRAIN SYSTEM. If the project proposes to replace and/or add connections to the City maintained storm drain system, then the applicant 11 1 0 4 0 1 may be responsible for improvements to the system. These improvements may include, but not limited to, upsizing the storm drain facility, replacing or adding City standard catch basins, pipes and manholes. THIS MAY INCLUDE REPLACING BRICK AND MORTAR MANHOLES. The extent of required improvements will be at the public works staff discretion and shall be consistent with Storm Drain Master Plan and Public Works Construction Standards. Any work on the city's storm drain systems requires permits and inspection by Public Works inspectors. 29. CCTV OF STORM DRAIN SYSTEM. Post construction the applicant may be required to provide CCTV inspection of the City’s storm drain facilities to verify that any lines were not broken, cracked or damaged during construction. The video shall be high resolution and done by professional who is familiar with the process and meticulous. A CCTV inspection video is required for new storm drain connection (s) to verify proper connections were made into the City’s system and that no construction material was left behind. Videos of storm drain system may also be required where construction occurred less than 5-ft from the city’s storm drain system. Videos shall be provided from structure to structure, such as manhole to manhole. Contractor may want to conduct their own inspection in advance of construction to verify the existing pipe integrity. If existing damages are located, they shall be reported to Public Works inspectors prior to the start of construction. If not reported, the contractor may be responsible to restore the pipe segment as determined by Public Works prior to final. 30. GEOTECHNICAL ENGINEER STATEMENT. The grading plans shall include the following statement signed and sealed by the Geotechnical Engineer of Record: “THIS PLAN HAS BEEN REVIEWED AND FOUND TO BE IN GENERAL CONFORMANCE WITH THE INTENT AND PURPOSE OF THE GEOTECHNICAL REPORT”. 31. SWPPP. This proposed development will disturb more than one acre of land. Accordingly, the applicant shall apply for coverage under the State Water Resources Control Board’s (SWRCB) NPDES general permit for storm water discharge associated with construction activity. A Notice of Intent (NOI) shall be filed for this project with the SWRCB in order to obtain coverage under the permit. The General Permit requires the applicant to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP). The applicant is required to submit two copies of the NOI and the draft SWPPP to the Public Works Department for review and approval prior to issuance of the building permit. The SWPPP should include both permanent, post-development project design features and temporary measures employed during construction. 32. ENCROACHMENT PERMIT. Prior to any work in the public right-of-way, the applicant shall obtain an encroachment permit from the Public Works Department for any work that encroaches onto the City right-of-way. 33. LOGISTICS PLAN. A construction logistics plan shall be provided addressing all impacts to the public including, at a minimum: work hours, noticing of affected businesses, bus 12 1 0 4 0 1 stop relocations, construction signage, dust control, noise control, storm water pollution prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance, Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may require an encroachment permit. 34. STORMWATER POLLUTION PREVENTION. All improvement plan sets shall include the “Pollution Prevention – It’s Part of the Plan” sheet. 35. C.3 THIRD-PARTY CERTIFICATION. Applicant shall provide certification from a qualified third-party reviewer that the proposed permanent storm water pollution prevention measures comply with the requirements of Provision C.3 and Palo Alto Municipal Code Chapter 16.11. Submit the following: a. Provide a stamped and signed C.3 data form (April 2024 version) from SCVURPPP. https://scvurppp.org/2024/09/19/provision-c-3-data-form-2024/ b. Final stamped and signed letter confirming which documents were reviewed and that the project complies with Provision C.3 and PAMC 16.11. 36. C.3 STORMWATER AGREEMENT. The applicant shall enter into a Stormwater Maintenance Agreement with the City to guarantee the ongoing maintenance of the permanent storm water pollution prevention measures. The City will inspect the treatment measures yearly and charge an inspection fee. The agreement shall be executed by the applicant team prior to building permit final. 37. C.3 FINAL THIRD-PARTY CERTIFICATION PRIOR TO OCCUPANCY. Within 45 days of the installation of the required storm water treatment measures and prior to the issuance of an occupancy permit for the building, the third-party reviewer shall submit to the City a certification verifying that all the permanent storm water pollution prevention measures were installed in accordance with the approved plans. 38. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (STORM DRAIN LOGO). The applicant is required to paint “No Dumping/Flows to Barron Creek” in blue on a white background adjacent to all onsite storm drain inlets. The name of the creek to which the proposed development drains can be obtained from Public Works Engineering. Stencils of the logo are available from the Public Works Environmental Compliance Division, which may be contacted at (650) 329-2598. Include the instruction to paint the logos on the construction grading and drainage plan. 39. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (RECORD DRAWINGS). At the conclusion of the project applicant shall provide digital as-built/record drawings of all improvements constructed in the public right-of-way or easements in which the City owns an interest. 13 1 0 4 0 1 40. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (INDEFINITE ENCROACHMENT PERMIT). An approved indefinite encroachment permit will be required for any private infrastructure constructed in the public right-of-way, easement or on property in which the City holds an interest, but that was not authorized by a building permit. Office of Transportation 41. PLAN SET REVISION REQUIRED PRIOR TO TRANSPORTATION APPROVAL. All items shall be addressed and incorporated into a revised plan set prior to Transportation approval. 42. FIRE ACCESS AND PARKING RESTRICTIONS. The fire truck path of travel shall include a "No Parking" sign. Signs meet the City's Fire Department requirements. 43. PARKING RESTRICTIONS. The curb along Old Trace Road shall be red-striped on both sides of the street to prevent parking within the fire truck path of travel. 44. SIGHT DISTANCE AND VISIBILITY. Sight triangles shall provide clear sight lines in accordance with stopping sight distance requirements in the Highway Design Manual. Landscaping, walls, or any features within sight distance triangles shall be restricted to a maximum height above the roadway surface. Per PAMC 16.24.020(5), fences exceeding four feet in height shall not be located within a sight distance triangle. a. The sight distance triangles shown on C1.2 shall be drawn to scale on the plan set and be prepared and signed by a traffic engineer. 45. BICYCLE FACILITIES. Dedicated bike lanes shown along the Arastradero Road frontage shall meet design standards and maintain a typical width of 5 feet. Green pavement markings are shown in the bicycle conflict zone on Arastradero Road. Per CA MUTCD 2026, green pavement is an optional treatment to alert users of a conflict zone but shall be accompanied by appropriate pavement marking patterns (dotted lines through the driveway). A detail showing dotted extension lines through the driveway apron per CA MUTCD 2026 shall be provided. a. Sharrow markings shall be removed from the plans for Arastradero Road, as no existing sharrows are present on the roadway. 46. PEDESTRIAN FACILITIES. For continuous pedestrian connection, a sidewalk shall be provided along Lots 8 and 9. New sidewalk shown on the project frontage shall conform to meet the City’s minimum standards. 47. DRIVEWAY & ACCESS STANDARDS. The minimum spacing between the two driveways, measured from radius return to radius return, shall be no less than 20 feet per PAMC 12.08.060(9)(A). 48. SIGNAGE AND TRAFFIC CONTROL DEVICES. A one-way sign shall be provided below the 14 1 0 4 0 1 stop sign on the new private street, and one sign shall be provided in the median island for right-turning traffic. All traffic control devices proposed in the public right-of-way (ROW) shall meet CA MUTCD requirements, including size, mounting height, and location. Review and approval shall be obtained as part of the offsite improvement plan. RRFB installation shall comply with CA MUTCD 2026, including any advance line markings or as otherwise required or recommended. A STOP bar shall be provided per CA MUTCD 2026 requirements. Offsite improvements shall be routed to Transportation for review and approval. Electrical Engineering – Utilities Department 49. CPAU STANDARDS. The plans shall be revised to callout all applicable CPAU Standards. Water Quality Division – Public Works Department 50. DETENTION GALLERY. The applicant shall clarify if a detention gallery will be required. If required, it shall be included as a part of the C3 Stormwater Treatment Plan. 51. STORMDRAIN CONNECTIONS. Direct connections to the storm drain system is not permitted. The plans shall be revised in accordance with Public Works Engineering standards and addressed at the time of the Streamlined Housing Development Review application. 52. STORMWATER MANAGEMENT PLAN. The proposed Stormwater Management Plan submitted under the Tentative Map application is not final and all stormwater treatment requirements for the project shall be adhered to in compliance with the Bay Area Municipal Regional Stormwater Permit. The Stormwater Management Plan in the development application (25PLN-00296) will take precedent. Water-Gas-Wastewater (WGW) Engineering – Utilities Department 53. PRIOR TO PLANNING ENTITLEMENT APPROVAL. The following comments are required to be addressed prior to Planning entitlement approval: a. A public utility easement for gas service on the private street for the gas main line will be recorded from property line to property line on the street. 54. PRIOR TO BUILDING PERMIT ISSUANCE. The following comments are required to be addressed prior to any future related permit application such as a Building Permit, Excavation and Grading Permit, Certificate of Compliance, Street Work Permit, Encroachment Permit, etc. These comments are provided as a courtesy and are not required to be addressed prior to the Planning entitlement approval: a. The gas main line will be located 5 feet away from the sewer line shown on-site towards the center of the private street. 15 1 0 4 0 1 b. The City of Palo Alto Utilities Department CPAU will design the gas main and provide the developer with an invoice for the design work by the City. Payment for the invoice is required before the City starts designing. Provide the WGW reviewer with a contact for the invoice to be sent. i. Schedule a meeting with CPAU reviewer once the estimated gas loads have been determined. CPAU will go over the steps for adding gas mains to the project. 55. PRIOR TO DEMOLITION PERMIT (IF REQUIRED). The applicant shall submit a request to disconnect utility services and remove gas meters. The utilities demo is to be processed within 10 working days after receipt of the request. The demolition permit will be issued by the building inspection division after all utility services and/or meters have been disconnected and removed. For Building Permit: 56. WGW SERVICE CONNECTION APPLICATION. The applicant shall submit a completed water-gas-wastewater service connection application - load sheet for the City of Palo Alto Utilities. The applicant must provide all the information requested for utility service demands (water in fixture units/g.p.m., gas in b.t.u.h, and sewer in fixture units/g.p.d.). The applicant shall provide the existing (prior) loads, the new loads, and the combined/total loads (the new loads plus any existing loads to remain). 57. IMPROVEMENT PLANS FOR UTILITY CONSTRUCTION. The applicant shall submit improvement plans for utility construction. The plans must show the size and location of all underground utilities within the development and the public right of way including meters, backflow preventers, fire service requirements, sewer mains, sewer cleanouts, sewer lift stations, and any other required utilities. Plans for new wastewater laterals and mains need to include new wastewater pipe profiles showing existing potentially conflicting utilities especially storm drain pipes, electric and communication duct banks. Existing duct banks need to be daylighted by potholing to the bottom of the duct bank to verify cross section prior to plan approval and starting lateral installation. Plans for new storm drain mains and laterals need to include profiles showing existing potential conflicts with sewer, water, and gas. 58. AUXILLARY WATER SUPPLY. The applicant must show on the site plan the existence of any auxiliary water supply, (i.e. water well, gray water, recycled water, rain catchment, water storage tank, etc). 59. UPGRADING EXISTING UTILITY MAINS/SERVICES. The applicant shall be responsible for installing and upgrading the existing utility mains and/or services, laterals as necessary to handle anticipated peak loads. This responsibility includes all costs associated with the design and construction for the installation/upgrade of the utility mains and/or services/laterals. 16 1 0 4 0 1 60. RPPA BACKFLOW PREVENTER DEVICE. An approved reduced pressure principle assembly (RPPA backflow preventer device) is required for all existing and new water connections from Palo Alto Utilities to comply with requirements of California administrative code, title 17, sections 7583 through 7605 inclusive. The RPPA shall be installed on the owner's property and directly behind the water meter within 5 feet of the property line. RPPA's for domestic service shall be lead free. Show the location of the RPPA on the plans. a. An approved reduced pressure detector assembly (RPDA backflow preventer device, STD. WD-12A or STD. WD-12B) is required for all existing and new fire water connections from Palo Alto Utilities to comply with requirements of California administrative code, title 17, sections 7583 through 7605 inclusive. The RPDA shall be installed on the owner's property and directly behind the City owned meter, within 5' (feet) of the property line or City Right of Way. 61. APPROVAL OF BACKFLOW PREVENTION DEVICE. All backflow preventer devices shall be approved by the WGW engineering division. Inspection by the city inspector is required for the supply pipe between the meter and the assembly. 62. PAYMENT OF CAPACITY AND CONNECTION FEES. The applicant shall pay the capacity fees and connection fees associated with new utility service/s or added demand on existing services. The approved relocation of services, meters, hydrants, or other facilities will be performed at the cost of the person/entity requesting the relocation. 63. FIRE SYSTEM USAGE. If a new water service line installation for fire system usage is required. Show the location of the new water service on the plans. The applicant shall provide to the engineering department a copy of the plans for fire system including all fire department's requirements. 64. WATER METERS. Each unit or building shall have its own water meter shown on the plans. Each parcel shall have its own water and sewer lateral connection shown on the plans. 65. SEWER LATERAL. A sewer lateral per lot is required. Show the location of the new sewer lateral on the plans. A profile of the sewer lateral is required showing any possible conflicts with storm, electric/communications ductbanks or other utilities. 66. ABANDONMENT OF EXISTING UTILITIES. All existing water, and gas. and wastewater services/laterals that will not be reused shall be abandoned at the main per the latest WGW utilities standards by CPAU. 67. LOCATION OF PROPOSED UTILITY CONNECTIONS. Utility vaults, transformers, utility cabinets, concrete bases, or other structures cannot be placed over existing water, gas, or wastewater mains/services. Maintain 1' horizontal clear separation from the 17 1 0 4 0 1 vault/cabinet/concrete base to existing utilities as found in the field. If there is a conflict with existing utilities, Cabinets/vaults/bases shall be relocated from the plan location as needed to meet field conditions. Trees may not be planted within 10 feet of existing water, gas, and wastewater mains/laterals/water services/or meters. New water or wastewater services/laterals/meters may not be installed within 10' of existing trees. Maintain 10' between new trees and new water and wastewater services/laterals/meters. 68. COPY OF FIRE SYSTEM PLAN. The applicant shall provide to the WGW Utility Engineering department a copy of the plans for fire system including all fire department's requirements prior to the actual service installation. 69. PALO ALTO CODE COMPLIANCE. All utility installations shall be in accordance with the City of Palo Alto utility standards for water, gas, & wastewater. SECTION 7. Term of Approval. Tentative Map. All conditions of approval of the Tentative Map shall be fulfilled prior to approval of a Final Map (PAMC Section 21.16.010[c]). Unless a Final Map is filed, and all conditions of approval are fulfilled within a two-year period from the date of Tentative Map approval, the Tentative Map shall expire and all proceedings shall terminate. A request for an extension of time may be granted by the City Council after recommendation of the planning commission, after the written extension request of the subdivider is submitted, prior to the expiration of the Tentative Map approval, or any previous extension granted. Such extension(s) shall be subject to the maximum limitations set forth in the Subdivision Map Act. // // // // // // // // INTRODUCED AND PASSED: AYES: NOES: ABSENT: ABSTENTIONS: 18 1 0 4 0 1 ATTEST: APPROVED: _________________________ ____________________________ City Clerk Mayor APPROVED AS TO FORM: APPROVED AS TO CONTENT: ___________________________ ___________________________ Assistant City Attorney City Manager ___________________________ Director of Planning and Development Services PLANS AND DRAWINGS REFERENCED: Those plans prepared by Steel Bridge Homes “THE OAKS SUBDIVISION TENTATIVE SUBDIVISION MAP” consisting of eleven pages, dated and submitted May 5, 2026. 1 0 6 0 0 ATTACHMENT C 4103 Old Trace Road, 25PLN-00298 1 Minimum Site Area, Width and Depth 1 acre, 100-foot width, 100-foot depth Multiple irregular shaped lots; see gross lot area for each lot below: Residential Density 1-2 units per acre per zoning. However, the Single-Family (SF) Residential Comprehensive Plan designation allows 1-7 dwelling units per acre (1.02 acres x 7 DU/acre = 7.16, rounded up to 8 units, plus 1 Density Bonus Law unit) Minimum Usable Open Space Not applicable None 1 Bold indicates an inconsistency with the requirement; however, where noted in the table the applicant is requesting a waiver to the development standards in accordance with allowances set forth under State Density Bonus Law. 1 0 6 0 0 Table 2: CONFORMANCE WITH CHAPTER 18.52 (Off-Street Parking) for Single-Family Residential3 Type Required Proposed Vehicle Parking 2 spaces, of which at least one space must be covered. No parking is required for ADU/JADUs 2 per single-family home = 9 covered spaces + 9 uncovered spaces = 18 parking spaces Parking to be proposed at the time of Streamlined Housing Development Review application and is anticipated to meet the minimum code requirement. Loading Spaces None None Bicycle Parking None None The application contains clear errors in right-of-way calculations and setbacks that materially affect the feasibility and legality of the project. The distance to the creek is misstated as 200 feet when it is, in fact, 145 feet. In addition, the plans appear to misapply the roadway centerline as defined in the Palo Alto Road Centerline Data Map, where the center of the median establishes the correct reference point. When the proper 45-foot setback is measured from the true centerline, the encroachment into the property is approximately 23 feet—not the 13 feet represented in the application. This is not a minor discrepancy; it fundamentally undermines the site design, placing required setbacks within the proposed building footprint of Lot 5B. The plans, as submitted, are therefore materially misleading. The proposal also fails to comply with the 53-foot special setback required along Arastradero Road, a designated scenic corridor. Four of the eight proposed homes are located within this protected setback area. The City’s Bonus Density provisions do not override these requirements under Section 20.08.020. These protections exist to preserve the character, safety, and environmental integrity of the corridor and have been consistently enforced on neighboring properties. There is no justification for waiving them in this case. Equally concerning are the public safety implications. Arastradero Road, west of Foothill Expressway, is a critical evacuation route for residents of Palo Alto and Los Altos Hills. Any development that compromises its function raises serious safety concerns. Internally, the project proposes a private roadway that is only 20 feet wide—far below the required 32 feet. This is inadequate for a subdivision of 5+ homes with driveway cuts of 16 feet instead of 20 feet. Safe two-way traffic and maneuvering will be nearly impossible during waste collection times, mail delivery or package drop off. The traffic study calculated 70 new trips a day for this development, which means during morning and evening commute times, any blockage along the short private road will cause cars to start backing up not on a side street but on the already congested Arastradero Road. The biggest safety impact for this development will be the new access point onto Arastradero. Adding a new intersection so close to Old Trace Road will put kids riding their bikes to school in serious danger because it adds more turning movements and unpredictability to an already busy road. It creates an avoidable and unacceptable safety hazard. While the need for housing is real, State housing laws do not exempt projects from complying with the Subdivision Map Act or from meeting basic health and safety standards. This proposal fails on both counts and is inconsistent with the City’s General Plan. Policy L-1.2 Retain undeveloped land west of Foothill Expressway and Junipero Serra as open space, with allowances made for very low-intensity development consistent with the open space character of the area. Finally, the proposal to allocate only 4% (approximately 1,900 square feet) of a 44,449-square-foot site to below-market-rate housing is grossly disproportionate to the scale of concessions and waivers requested. The public benefit does not justify the significant deviations from established standards. Additionally, consistent information throughout the submitted plans would be extremely helpful. As is, it’s impossible to know the exact plans. Perhaps that’s the intent. For all of these reasons, I urge the City Council to deny this project in its current form. At a minimum, the applicant must be required to correct these errors and fully comply with all applicable regulations before any consideration of approval. Thank you for your time and attention to this matter. Sincerely, Katherine Clancy 4146 Old Trace Road Palo Alto, CA 94306 Jeannie Clancy 4/16/26, 4:34 PM Re: 4103 Old Trace Road - Kandikuppa, Nishita - Outlook about:blank?windowId=SecondaryReadingPane6 2/2 goals. I have copied the lead planner for the SCPO update on this email to raise awareness of this apparent inconsistency. I look forward to your clarification on how the City intends to resolve this contradiction. Best regards, Jeff Watt (resident, Esther Clark Park neighborhood) 4/20/26, 6:01 PM CEQA exemption (AB 130) for 4103 Old Trace Road - Kandikuppa, Nishita - Outlook about:blank?windowId=SecondaryReadingPane18 2/2 additional "road", which would allow for some increased density without creating such an anomaly in the neighborhood. Gaile Gordon Palo Alto resident on Manuela Ave. 5/1/26, 1:36 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQADl2dddcjzJNvIkGv1bJD%2B…2/2 Memorandum Date: April 20, 2026 To: Ms. Melanie Griswold, Trace Estates, LLC From: Gary Black, AICP Daniel Choi Miles Henninger Subject: VMT Screening Analysis and Design Review for a Residential Development at 4103 Old Trace Road in Palo Alto, California Hexagon Transportation Consultants, Inc. has completed Vehicle Miles Traveled (VMT) screening analysis and a traffic design analysis for the proposed residential development located at 4103 Old Trace Road in Palo Alto, California. The project site location is shown on Figure 1. The project site plan is shown on Figure 2. The project proposes to construct 9 single-family homes (5 detached and 4 attached) on a vacant lot. Seven of the single-family homes would contain a junior accessory dwelling unit (JADU). Project Trip Generation Through empirical research, data have been collected that indicate the amount of traffic that can be expected to be generated by common land uses. Project trip generation was estimated by applying to the size and uses of the development the appropriate trip generation rates. The average trip generation rates for Single-Family Detached Housing (Land Use 210), Single-Family Attached Housing (Land Use 215), and Multifamily Housing (Low-Rise) (Land Use 220) as published in the Institute of Transportation Engineers (ITE) Trip Generation Manual, 12th Edition (2025) were applied to the proposed project. The JADUs are not expected to generate any trips on their own. They are part of the main house and are typically used by family members or guests instead of long-term tenants. Table 1 Trip Generation Land Use Rate Trips Rate In Out Total Rate In Out Total Proposed Project #210 - Single-Family Detached Housing 5 Dwelling Units 9.09 45 0.70 1 3 4 0.93 3 2 5 #215 - Single-Family Attached Housing 4 Dwelling Units 6.57 26 0.47 1 1 2 0.51 1 1 2 Total Project Trips 71 2 4 6 4 3 7 Source: ITE Trip Generation Manual (12th Edition, 2025) Trip generation rate for the proposed residential uses are based on average rates found in the ITE's Trip Generation Manual, 12th Edition rates for Land Use 210 "Single-Family Detatched Housing - General Urban/Suburban" and for Land Use 215 "Single-Family Attached Housing - General Urban/Suburban". PM Peak HourAM Peak Hour Size Trips TripsDaily Palo Alto Arast r a d e r o R d Foot h i l l E x p y Miran d a A v e Foo t h i l l E x p y Mira n d a A v e Hil l v i e w A v e Old T r a c e R d Old A d o b e R d Arast r a d e r o R d Foot h i l l E x p y Miran d a A v e Foo t h i l l E x p y Mira n d a A v e Hil l v i e w A v e Old T r a c e R d Old A d o b e R d = Site Location LEGEND 4103 Old Trace Road VMT Screening and Design Review Figure 1 Site Location 4103 Old Trace Road VMT Screening and Design Review Figure 2 Project Site Plan 4103 Old Trace Road VMT Screening and Design Review April 20, 2026 Page | 4 Based on the trip generation rates, it is estimated that the project would generate 71 daily trips, with 6 trips in the AM peak hour and 7 trips in the PM peak hour. The City’s Local Transportation Analysis (LTA) Policy requires an LTA for projects that generate more than 50 peak hour trips. Since the project would generate fewer than 50 peak-hour trips, an LTA analysis is not required. Vehicles Miles Traveled The City of Palo Alto provides screening criteria to determine whether a development project would be required to conduct a VMT analysis. Projects that meet the screening criteria would be presumed to have a less than significant impact on VMT and would not be required to conduct a detailed VMT analysis. The city has the following screening criteria for development projects: • Small Developments (projects that generate fewer than 110 trips per day) • Projects in Low-VMT Areas (projects located in low-VMT areas that have similar features to existing developments) • Projects in Proximity to Major Transit Stops (projects located within ½ mile of an existing or planned high quality transit corridor or major transit stop) • Affordable Housing (100% affordable housing projects in infill locations) • Local-Serving Retail (retail projects of 10,000 s.f. or less) • Transportation Projects (roadway, transit, bicycle, and pedestrian projects that do not lead to a measurable increase in vehicle travel) Since the project is anticipated to generate 71 daily trips, the project would meet the small development screening criterion and can be presumed to have a less than significant impact on VMT. Palo Alto Comprehensive Plan and Housing Element Update The project site is included in the City’s 2030 Comprehensive Plan. The 2030 Comprehensive Plan included 13 additional housing units within the project’s zone. The City adopted their new Housing Element in May 2023, for which an environmental impact report (EIR) was prepared. The Housing Element was approved as an addendum to the Comprehensive Plan. Therefore, projects that are consistent with the Comprehensive Plan are presumed to have their transportation impacts included in the analysis conducted for the Housing Element Update. The proposed project’s 9 single-family residences is within number of units included in the Comprehensive Plan and would not change the conclusions of the findings of the EIR prepared for the Housing Element Update. Roadway Width Analysis The development’s 9 lots would be served by a private roadway with a 30.5-foot-wide right-of-way and a 20-foot curb-to-curb width. No parking would be allowed along the entire length of the roadway. Section 21.20.240 of the Palo Alto Municipal Code requires a minimum right-of-way width of 32 feet for private roadways serving five or more lots, or a minimum of 22 feet for private roadways serving fewer than five lots. Appendix D of the California Fire Code stipulates that fire apparatus access roads must be a minimum of 20 feet wide. Fire apparatus turning templates (shown in Figure 3) indicate that fire trucks could adequately navigate the proposed roadway. As such, the proposed road would not pose issues for fire truck access. Furthermore, the 2018 edition of the American Association of 4103 Old Trace Road VMT Screening and Design Review April 20, 2026 Page | 5 State Highway and Transportation Officials’ A Policy on Geometric Design of Highways and Streets stipulates that the minimum lane width for residential streets in developed areas should be 9-10 feet. Due to the small scale of the development and associated low traffic volume, the 20-foot width of the roadway would be suitable for vehicular circulation throughout the site. Figure 3 Fire Apparatus Turning Templates 4103 Old Trace Road VMT Screening and Design Review HSW LLP VIA ACCELA & EMAIL March 30, 2026 Ms. Nishita Kandikuppa, Planner Ms. Claire Raybould, Acting Planning Manager City of Palo Alto Planning & Development Department Development Center 285 Hamilton Avenue, Suite 100 Palo Alto, CA 94301 Re: Updated Project Letter for Tentative Map Component of Proposed Residential Subdivision (“The Oaks”) at 4103 Old Trace Road, Palo Alto, CA 94306 (APN 175-20-078) Dear Ms. Raybould and Ms. Kandikuppa, Enclosed you will the requested resubmittal information for the tentative map application (25 PLN-0296) for a “housing development project,” as defined in the Housing Accountability Act (“HAA”) (Gov. Code § 65589.5) and a proposed residential subdivision known as “The Oaks” located at 4103 Old Trace Road within the City of Palo Alto, California 94306. The specifics related to the Tentative Map application are set forth below. A Streamlined Housing Permit (25PLN-00298) is being processed separately and contains further detail on the proposed units. I. PROJECT DESCRIPTION. The proposed project (“Project”) is a “mixed-income”, all residential “housing development project” consisting of a tentative map application to subdivide one (1) 1.02 gross acre vacant lot at 4103 Old Trace Road, Palo Alto, CA into (9) residential lots and one (1) common area lot for a private street, utilities, access, stormwater treatment facilities, and other improvements. These lots are being planned to accommodate one single-family and junior accessory dwelling unit (“JADU”) (2 units each/10 units total) on each of Lots 1 through 5 and one attached single- family dwelling and JADU on each of Lots 6 and 7 (2 unit each/4 units total) and one attached single-family dwelling unit on each of Lots 8 and 9 (2 units total). The Applicant is seeking one (1) density bonus lot/unit based on its provision of one (1) lot/unit that will be deed-restricted to households earning no more than 100% of AMI. The Applicant is also seeking waivers, reductions in development standards, incentives and concessions consistent with State Density Bonus Law (“SDBL”) (Gov. Code § 69515, et seq.). 4103 Old Trace Road – Subdivision App Melanie Griswold mg@hsw-legal.com 415-265-186 II. CEQA EXEMPTION The Project has been designed to be exempt from CEQA review under AB130. Detail was previously provided to the City establishing the Project’s eligibility. The Applicant seeks the City’s confirmation that the Project has been found to be exempt. III. DENSITY BONUS INFORMATION. A. Base Density & Density of the Project. The base density of this site is 8 primary dwelling units per acre. The applicant is proposing to deed-restrict 12.5% of the units. At the tentative map stage, this translates into 1 lot (Lot 9), which will contain one (1) attached single-family dwelling unit that is deed-restricted as affordable to moderate-income households earning no more than 100% of AMI. By providing this affordable unit, the Applicant is entitled to a 7% density bonus. This translates into one (1) additional primary dwelling unit, which is being planned for Lot 7.0F 1 B. Assurances for the Affordability of Units. Upon request, the Applicant will record a deed-restricted covenant prior to recordation of final map to ensure compliance with the proposed affordability and pre-conditions for eligibility for SDBL. If the Streamlined Housing Permit is approved first, the Applicant would also accept a condition of approval that regarding recordation of a deed-restriction before issuance of any building permits. C. Density Bonus Waivers and Reductions in Development Standards. The applicant requests the following waivers and reductions in development standards pursuant to SDBL: 1. Reduce minimum lot size in RE-1 zone as provided in PAMC § 18.10.040(a) at Table 2 from 1 acre and minimum 6,000 SF size in PAMC § 21.20.100 to a minimum of 1,921 SF (Gross) and 1,570 (Net). If the minimum lot area were not permitted, it would eliminate all of the residential lots except 1, thereby precluding the allowed density 2. Decrease front setback from 30’ provided in PAMC § 18.10.040(a) at Table 2 to a minimum of 9.5’ as measured from back of curb for Lots 1 through 5 and 5’ as measured from back of curb for Lots 6 through 9. As shown below in RED, a 30’ setback would substantially reduce the proposed buildable area of all lots, thereby reducing density. 1 As noted previously, for the purposes of base density and density bonuses, JADUs are disregarded unless they are being deed-restricted to obtain density bonus benefits 4103 Old Trace Road – Subdivision App Melanie Griswold mg@hsw-legal.com 415-265-186 3. Decrease interior side setbacks as provided in PAMC § 18.10.040(a) at Table 2 from 15’ to 5’. As shown above in GREEN, a 15’ interior setback would substantially reduce the proposed buildable area of each of lots, thereby reducing buildable area on all of the proposed lots. 4. Decrease rear setbacks as provided in PAMC § 18.10.040(a) at Table 2 from 30’ to 10’ on Lots 1 and 3 through 9. On Lot 2, decrease the rear setback to 5’. As shown below in PURPLE, a 30’ setback would substantially reduce the proposed buildable area of all lots, thereby reducing density. 4103 Old Trace Road – Subdivision App Melanie Griswold mg@hsw-legal.com 415-265-186 5. Reduce the special setback on Arastradero on Lot 5 from 53’ to 9.5’ and Lots 6 through 8 from 53’ to 15’. 4103 Old Trace Road – Subdivision App Melanie Griswold mg@hsw-legal.com 415-265-186 6. Reduce the minimum width of the private street from 32’ as required by PAMC § 21.20.240(b)(4) to 20’. As shown below in BLUE, increasing the street width would eliminate buildable area on Lots 1 through 5, thereby reducing density. 7. Reduce the requirement that no parking spaces are to be located in a required front yard per PAMC § 18.12.060(c)(1) to match the required front yards with the requested waivers herein for Lots 1 through 5. All of the garages are located in the required front yard for the R-E zone and, without a derivative waiver for this requirement, all of the garages would be eliminated on Lots 1 through 5. 8. Reduce the minimum site depth from 100’ as required by PAMC § 18.10.040(a) at Table 2 to 59’78’. If the minimum were imposed, it would only allow one conforming lot instead of the 9 residential lots proposed, thereby reducing density. If the minimum were imposed, it would only allow two (2) conforming lot as shown roughly below in RED instead of the 9 residential lots proposed, thereby reducing density. 9. Reduce the minimum site width from 100’ as required by PAMC § 18.10.040(a) at Table 2 and PAMC § 21.20.100 to the minimum on Lot 9 (approx. 30’). If the minimum were imposed, it would only allow two (2) conforming lot as shown roughly below in RED 4103 Old Trace Road – Subdivision App Melanie Griswold mg@hsw-legal.com 415-265-186 instead of the 9 residential lots proposed, thereby reducing density. Further waivers are reserved pending comments and feedback on the proposed Project. D. Incentives and Concessions. The applicant anticipates requesting incentive related to the size of the affordable housing unit planned on Lot 9. This will be requested and developed during the Streamlined Housing Permit process and is reserved at this time. ************ We appreciate your assistance so far and look forward to bringing much-needed housing to the City of Palo Alto. If you have any questions or need further information, I can be reached at 415- 265-1086 or mg@hsw-legal.com. Kind regards, Melanie Griswold, Partner HSW LLP Order Number: 3630425-01971 Cornerstone Title Company 506 N Santa Cruz Avenue Los Gatos, CA 95030 PH: (408) 354-0502 FX: (303) 323-6516 Melanie Griswold Steel Bridge Capital LLC 206 Garden Hill Drive Los Gatos, CA 95032 Escrow Officer: Charlene Ramos Email: charlene.ramos@cstitleco.com Assistant: Ramos Team Email: ramosteam@cstitleco.com Escrow Number: 3630425-01971 Owner: Steel Bridge Homes Palo Alto, LP Property: Vacant Land, known as APN 175-20-078 also knows as 4103 Old Trace Road Palo Alto, CA 94306 Order Number: 3630425-01971 Cornerstone Title Company PRELIMINARY REPORT In response to the above referenced application for a policy of title insurance, this company hereby reports that it is prepared to issue, or cause to be issued, as of the date hereof, a Policy or Policies of Title Insurance describing the land and the estate or interest therein hereinafter set forth, insuring against loss which may be sustained by reason of any defect, lien or encumbrance not shown or referred to as an Exception below or not excluded from coverage pursuant to the printed Schedules, Conditions and Stipulations of said Policy forms. The printed Exceptions and Exclusions from the coverage and Limitations on Covered Risks of said policy or policies are set forth in Exhibit B attached. The policy to be issued may contain an arbitration clause. When the Amount of Insurance is less than that set forth in the arbitration clause, all arbitrable matters shall be arbitrated at the option of either the Company or the Insured as the exclusive remedy of the parties. Limitations on Covered Risks applicable to the CLTA and ALTA Homeowner's Policies of Title Insurance which establish a Deductible Amount and a Maximum Dollar Limit of Liability for certain coverages are also set forth in Exhibit B. Copies of the policy forms should be read. They are available from the office which issued this report. Please read the exceptions shown or referred to below and the exceptions and exclusions set forth in Exhibit B of this report carefully. The exceptions and exclusions are meant to provide you with notice of matters which are not covered under the terms of the title insurance policy and should be carefully considered. It is important to note that this preliminary report is not a written representation as to the condition of title and may not list all liens, defects, and encumbrances affecting title to the land. This report (and any supplements or amendments hereto) is issued solely for the purpose of facilitating the issuance of a policy of title insurance and no liability is assumed hereby. If it is desired that liability be assumed prior to the issuance of a policy of title insurance, a Binder or Commitment should be requested. Order Number: 3630425-01971 Cornerstone Title Company Dated as of August 27, 2025 at 7:30 A.M. The form of Policy of title insurance contemplated by this report is: ALTA/CLTA Homeowner's Policy of Title Insurance (2013), if applicable, or CLTA/ALTA Standard Owner's Policy 1990; and/or ALTA Loan Policy (2021). A specific request should be made if another form or additional coverage is desired. Title to said estate or interest at the date hereof is vested in: Steel Bridge Homes Palo Alto, LP, a California Limited Partnership The estate or interest in the land hereinafter described or referred to covered by this Report is: A Fee The Land referred to herein is described as follows: (See attached Legal Description) At the date hereof exceptions to coverage in addition to the printed Exceptions and Exclusions in said policy form would be as follows: 1. General and special taxes and/or assessments for the fiscal year 2025-2026, a lien, but not yet due or payable. 2. The lien of supplemental taxes, if any, assessed pursuant to the provisions of Section 75, et seq. of the Revenue and Taxation Code of the State of California. Please note that there may be a supplemental or an escaped assessment of taxes which will possibly be assessed due to the conveyance of said land or may be triggered due to the death of a prior owner. The Company makes no representations and is not responsible for identifying the amount or time period in which said taxes will be assessed against the subject property. 3. Water rights, claims or title to water, whether or not shown by the public records. 4. Easements, recitals, setbacks, and other matters affecting that portion of said land for the purposes stated thereon and incidental purposes as shown upon a filed map Filed: Book 293, Page 29 Order Number: 3630425-01971 Cornerstone Title Company 5. A Deed of Trust to secure an original indebtedness and any other amounts or obligations secured thereby Amount: $4,000,000.00 Dated: May 22, 2025 Trustor:Steel Bridge Homes Palo Alto, LP a California Limited Partnership Trustee: Chicago Title Company Beneficiary Youland Inc., a California corporation Recorded:May 30, 2025 as Instrument No. 25814693 of Official Records 6. Rights of parties in possession. 7. Rights of parties in possession of said land by reason of any unrecorded leases. Please submit any such leases to this company for our examination. 8. Any facts, rights, interests or claims which would be disclosed by a correct ALTA/NSPS Survey and/or inspection of said land. Order Number: 3630425-01971 Cornerstone Title Company REQUIREMENTS Prior to closing this company will require the following: 1. The requirement that the owner's property statement be executed and upon review further requirements may be requested prior to the issuance of any policy of insurance. 2. This transaction may be subject to an order issued pursuant to the Bank Secrecy Act. The policy issuing agent may need to provide certain information necessary to comply with the order prior to the closing. 3. The requirement that underwriting approval be obtained if any policy of title insurance is requested other than a standard owners policy. 4. The company may require a copy of a valid government issued photo ID from the Principle(s) involved in this transaction subject to further requirements of this company. 5. Should this report be used to facilitate your transaction, we must be provided with the following prior to the issuance of the policy: A. A certified copy of the certificate of limited partnership (form LP-1) and any amendments thereto (form LP-2) to be recorded in the public records; B. A full copy of the partnership agreement and any amendments; Satisfactory evidence of the consent of a majority in interest of the limited partners to the contemplated transaction; C. Other requirements which the Company may impose following its review of the above material and other information which the Company may require. 6. The requirement that High Liability approval be obtained prior to the close and issuance of any policy of title insurance. The High Liability process must be completed according to the Policy Underwriter’s requirements. Order Number: 3630425-01971 Cornerstone Title Company INFORMATIONAL NOTES Note: The policy to be issued may contain an arbitration clause. When the Amount of Insurance is less than the certain dollar amount set forth in any applicable arbitration clause, all arbitrable matters shall be arbitrated at the option of either the Company or the Insured as the exclusive remedy of the parties. If you desire to review the terms of the policy, including any arbitration clause that may be included, contact the office that issued this Commitment or Report to obtain a sample of the policy jacket for the policy that is to be issued in connection with your transaction. 1. Said property appears to be Vacant Land, known as APN 175-20-078, also known as 4103 Old Trace Road, Palo Alto, CA 94306. 2. General and special taxes and/or assessments for the fiscal year 2024-2025, as follows: Assessor’s Parcel Number: 175-20-078 TRA: 006-020 First Installment: $2,748.14 Paid Second Installment: $2,748.14 Paid 3. There are no conveyances affecting said land within two (2) years of the date of this report, except the following: A Deed recorded May 30, 2025 as Instrument Number 25814692, Official Records Dated: March 25, 2025 Grantor: Linda Jean Brennan, Successor Trustee under the Smithwick Living Trust, dated October 15, 1998 Grantee: Steel Bridge Homes Palo Alto, LP a California Limited Partnership 4. The map attached, if any, may or may not be a survey of the land depicted hereon. Cornerstone Title Company expressly disclaims any liability for loss or damage which may result from reliance on this map except to the extent coverage for such loss or damage is expressly provided by the terms and provisions of the title insurance policy, if any, to which this map is attached. Order Number: 3630425-01971 Cornerstone Title Company LEGAL DESCRIPTION All that certain real property situated in the City of Palo Alto, County of Santa Clara, State of California, described as follows: All of Parcel 4, as shown upon that certain Map entitled, "Parcel Map, Portion of Lot 7, Briones Partition", which Map was filed for record in the Office of the Recorder of the County of Santa Clara, State of California, on November 26, 1971 in Book 293 of Maps, at Page 29. APN: 175-20-078 Order Number: 3630425-01971 Cornerstone Title Company TH I S M A P I S F O R Y O U R A I D I N L O C A T I N G Y O U R L A N D I N R E F E R E N C E T O S T R E E T S A N D O T H E R P A R C E L S . W H I L E T H I S M A P I S B E L I E V E D T O B E C O R R E C T , T H E C O M P A N Y A S S U M E S N O L I A B I L I T Y F O R A N Y L O S S O C C U R R I N G B Y R E A S O N O F R E L I A N C E T H E R E O N . Order Number: 3630425-01971 Cornerstone Title Company NOTICE Section 12413.1 of the California Insurance Code, effective January 1, 1990, requires that any title insurance company, underwritten title company, or controlled escrow company handling funds in an escrow or sub-escrow capacity, wait a specified number of days after depositing funds, before recording any documents in connection with the transaction or disbursing funds. This statute allows for funds deposited by wire transfer to be disbursed the same day as deposit. In the case of cashier's checks or certified checks, funds may be disbursed the next day after deposit. In order to avoid unnecessary delays of three to seven days, or more, please use wire transfer, cashier's checks, or certified checks whenever possible. If you have any questions about the effect of this new law, please contact your escrow office for more details. Attachment G Project Plans In order to reduce paper consumption, a limited number of hard copy project plans are provided to Council Members for their review. The same plans are available to the public, at all hours of the day, via the following online resources. Directions to review Project plans online 1. Go to: bit.ly/PApendingprojects 2. Scroll down to find “4103 Old Trace Road” and click the address link 3. On this project specific webpage, you will find a link to the project plans and other important information Direct Link to Project Webpage 4103 Old Trace Road – City of Palo Alto, CA Item No. 12. Page 1 of 3 1 0 0 0 4 City Council Supplemental Report From: Jonathan Lait, Planning and Development Services Director Meeting Date: May 18, 2026 Item Number: 12 Report #:2605-6369 TITLE PUBLIC HEARING / QUASI-JUDICIAL. 4103 Old Trace Road [25PLN-00298]: Request for Approval of a Tentative Map to Allow for the Subdivision of a Vacant 1.02-Acre Lot to Create Nine Residential Lots and One Private Street to Facilitate Construction of Nine New Single-Family Residences and Seven Junior Accessory Dwelling Units (25PLN-00296). CEQA Status: Exempt Pursuant to Assembly Bill 130 (Public Resources Code Section 21080.66). Zone District: RE (Residential Estate) RECOMMENDATION Staff recommends that Council adopt an updated Record of Land Use Action (RLUA) incorporating revised conditions of approval from the Electrical Utilities Division. BACKGROUND This report provides revised conditions of approval from the Electrical Engineering Division under the Utilities Department for the 4103 Old Trace Tentative Map application. The revised conditions are as follows: 1. TRENCHING. The proposed trench shall meet the City of Palo Alto Utilities (CPAU) clearance requirements. 2. ELECTRICAL BOX AND CONDUITS. The electrical boxes and conduit requirements shall be finalized during the building permit application. No load calculations or requested service sizes have been provided as a part of this application but shall be finalized at the time of streamlined housing development application. 3. ELECTRICAL LOAD CALCULATIONS. CPAU scope may change based on estimated load calculations at the time of building permit application. 4. TRANSFORMER CLEARANCE. The proposed transformers shall maintain a minimum clearance of 3 feet on all sides except the front which shall have a clearance of 8 feet. A minimum distance of 10 feet shall be maintained from any proposed windows and doors. 5. EASEMENTS. All electrical easements will be required to be granted to CPAU for CPAU electric utility boxes and conduits per CPAU regulations and standards. Item No. 12. Page 2 of 3 1 0 0 0 4 6. STREETLIGHT MAINTENANCE. All privately owned streetlights shall be maintained by the applicant. Additionally, this report provides brief supplementary analysis of two primary issues raised in public comment for this item: 1) that the City Council should deny the application because the project is inconsistent with the City’s objective standards for the RE zone; and 2) that the City should deny the application because the project will create substantial public safety issues. 1.For purposes of state housing laws, the proposed tentative map at 4103 Old Trace Road is consistent with the City’s objective standards. The Housing Accountability Act (Gov. Code 65589.5) strictly limits the City’s discretion for housing development projects that comply with applicable, objective local standards. When determining whether a project complies with such standards, “the receipt of a density bonus, incentive, concession, waiver, or reduction of development standards pursuant to [State Density Bonus Law] shall not constitute a valid basis on which to find a proposed housing development project is inconsistent.” (Gov. Code 65589.5, subd (j)(3).) As explained in the staff report, the proposed tentative map must be considered consistent with the City’s standards for the RE zone because the Comprehensive Plan Land Use Element allows a density ranging up to seven units per acre in this zone. Even though the zoning code provides a density of one unit per acre, State Density Bonus Law requires that the City apply the highest density allowed in the City’s planning documents. (Gov. Code 65915, subd. (o)(6).) In addition, because the project qualifies for a density bonus, the City must also provide unlimited waivers from physical development standards, including street width, lot size, and setback/special setback. 2.The Project will not have a specific, adverse impact on public health and safety that cannot be mitigated. The City may only deny a waiver or deny/reduce the density of the project if it finds that the wavier or project approval will have a specific, adverse impact on public health and safety that cannot be mitigated. (Gov. Code 65915, subd. (e)(1) and 65589.5, subd. (j)(1).) (footnote: The City may also deny a waiver on the following bases, which are not relevant to 4103 Old Trace Road project: (1) the waiver would be contrary to state or federal law; or (2) the waiver would have a specific, adverse impact on real property listed in the California Register of Historic Resources.) “Specific, adverse impact” means “a significant, quantifiable, direct, and unavoidable impact on public health and safety, based on objective, identified written public health or safety standards.” (Gov. Code 65589.5, subd. (j)(1).) The public health and safety concerns raised in public comment before the ARB and PTC Item No. 12. Page 3 of 3 1 0 0 0 4 do not rise to the level of “specific, adverse impacts” as defined in state law. Safety concerns generally relate to emergency vehicle access to Old Trace Road and conflicts between cars and bicycles/pedestrians. As explained in the staff report, the concern regarding emergency vehicle access is an existing condition that will be improved by the project. With respect to bicycle and pedestrian safety, the project was evaluated against objective traffic management standards by the Office of Transportation and was found not to warrant any intervention. The applicant is voluntarily adding a flashing crosswalk to improve conditions. ATTACHMENTS Attachment A: Draft Record of Land Use Action APPROVED BY: Jonathan Lait, Planning and Development Services Director 1 1 1 6 2 2 DRAFT ACTION NO. 2026-__ At its meeting on ____________, the City Council of the City of Palo Alto (“City Council”) _____________the Tentative Map to subdivide a vacant lot into nine residential lots, making the following findings, determinations and declarations: SECTION 1. Background. A. On November 7, 2025, Steel Bridge Homes Palo Alto submitted a subdivision map application for a Tentative Map to subdivide a vacant lot into nine residential lots at 4103 Old Trace Road (“The Project”). The project site is a vacant 1.02-acre lot situated at the intersection of Arastradero Road and Old Trace Road (APN 175-20-078). Adjacent uses include a mix of one- and two-story single- family residences to the east, west and south and a research facility to the north. B. Following staff review, the Planning and Transportation Commission reviewed the project and recommended unanimous approval on April 29, 2026, subject to conditions of approval. C. On _____________2026, the City Council held a public hearing in accordance with the City Council’s policies and procedures and __________the project subject to conditions of approval. SECTION 2. Environmental Review. The City, as the lead agency for the Project, has determined the project is exempt from California Environmental Quality Act (CEQA) in accordance with AB 130 [Public Resources Code section 21080.66]. Documentation to support the streamlined review is available as part of the public record on file with the Planning and Development Services Division. SECTION 3. Tentative Map Findings. A legislative body of a city shall deny approval of a Subdivision Map, if it makes any of the following findings (California Government Code Section 66474). The City Council cannot make these findings for the following reasons: 2 1 1 6 2 2 1.That the proposed map is not consistent with applicable general and specific plans as specified in Section 65451: There is no adopted specific plan for this project site. The site is consistent with the Comprehensive Plan as described below. 2.That the design or improvement of the proposed subdivision is not consistent with applicable general and specific plans: There is no adopted specific plan for this project site. The proposed Tentative Map and related improvements are consistent with the Comprehensive Plan in that it facilitates housing development on a site designated for single-family use within the urban services area, consistent with Policy L-1.3 of the Land Use Element and Policy 3.2 of the Housing Element. The proposed density is consistent with the range of densities provided in the Land Use Element, as modified by State Density Bonus law. The Project includes nine residential lots, each with a single-family residence; seven of the nine residences include Junior Accessory Dwelling Units (JADUs). One of the single-family residences is provided at a rate affordable to moderate- income households earning no more than 100% of the Area Median Income (AMI). The Project proposes in-fill development and contributes to the housing inventory. 3. That the site is not physically suitable for the type of development: The Project site is suitable for single-family residential development in that the Comprehensive Plan land use designation of “Single Family Residential allows for detached single-family residential neighborhoods with net densities ranging from 1-7 units per acre and can increase up to 14 units per acre on parcel that include a second unit or duplex. The proposed number of single-family units created on the resulting parcels complies with the applicable densities set forth in the land use element and zoning code. In addition, the Project is proposed pursuant to the State Density Bonus Law and Housing Accountability Act (Government Code section 65589.5) and is consistent with the standards set forth therein. 4.That the site is not physically suitable for the proposed density of development: The proposed project consists of one single-family residence on each of the nine resulting lots, which is permitted use within the Residential Estate (RE) zoning district. In addition, Junior Accessory Dwelling Units (JADUs) are proposed on seven of the nine lots. Pursuant to State ADU law, the JADUs are considered accessory to the primary dwelling units and are not counted toward the maximum allowable residential density. The base density for the site is calculated at 7 dwelling units on a 1.02-acre lot, resulting in a fractional density of 7.14, rounded up to 8 dwelling units per acre pursuant to Palo Alto Municipal Code (PAMC) Section 18.15.020(u). The applicant proposes a total of 9 dwelling units, including one affordable unit, and is therefore entitled to a 7% density bonus pursuant to State Density Bonus Law. Accordingly, the proposed 3 1 1 6 2 2 density of 9 dwelling units per acre is consistent with the density permitted under State Density Bonus Law. 5. That the design of the subdivision or the proposed improvements are likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat: 6. That the design of the subdivision or type of improvements is likely to cause serious public health problems: 7. That the design of the subdivision or the type of improvements will conflict with easements, acquired by the public at large, for access through or use of, property within the proposed subdivision. In this connection, the governing body may approve a map if it finds that alternate easements, for access or for use, will be provided, and that these will be substantially equivalent to ones previously acquired by the public. This subsection 4 1 1 6 2 2 shall apply only to easements of record or to easements established by judgment of a court of competent jurisdiction and no authority is hereby granted to a legislative body to determine that the public at large has acquired easements for access through or use of property within the proposed subdivision. There are no public access easements over the property currently. Therefore, the design of the subdivision will not conflict with any public easements for access through, or use of, the property. New public utility easements will be provided to existing and proposed electrical utilities as part of this subdivision map as required in accordance with City of Palo Alto Utilities standards. A new 20-foot private street will be provided to provide access to the proposed residential lots, including an additional 10 feet width along Lots 6, 7 and 8 to provide a 4-foot wide sidewalk, consistent with project plans. SECTION 4. Tentative Map Approval Granted. Tentative Map Approval is filed and processed in accordance to PAMC Section 21.12.090 and granted by the City Council under PAMC Sections 21.12 and 21.20 and the California Government Code Section 66452, subject to the conditions of approval in Section 6 of this Record of Land Use Action. SECTION 5. Final Map. The Final Map submitted for review and approval by the City Council shall be in substantial conformance with the Tentative Map prepared by Steel Bridge Homes titled “THE OAKS SUBDIVISION TENTATIVE SUBDIVISION MAP” consisting of eleven pages, dated and submitted May 5, 2026, except as modified to incorporate the conditions of approval in Section 6. A copy of the Tentative Map is on file in the Department of Planning and Development Services, Current Planning Division. Prior to the expiration of the Tentative Map approval, the subdivider shall cause the subdivision or any part thereof to be surveyed, and a Final Map, as specified in Chapter 21.08, to be prepared in conformance with the Tentative Map as conditionally approved, and in compliance with the provisions of the Subdivision Map Act and PAMC Title 21 and submitted to the City Engineer (PAMC Section 21.16.010[a]). SECTION 6. Conditions of Approval. Planning 1. PROJECT PLANS. The Final Map submitted for review and approval by the City Council shall be in substantial conformance with the Tentative Map titled “THE OAKS SUBDIVISION TENTATIVE SUBDIVISION MAP”, prepared by Steel Bridge Homes and submitted May 5, 2026, except as modified to incorporate the conditions of this approval. 2. FINAL MAP COVER PAGE. At such time as the Final Map is filed, the cover page shall include the name and title of the Director of Planning and Development Services. 3. DEVELOPMENT IMPACT FEES. The Property Owner or their designee shall pay all applicable development impact fees associated with the proposed development and 5 1 1 6 2 2 subdivision prior to issuance of the building permit(s) or recordation of the Final Map. Impact fees may be paid prior to occupancy in accordance with the requirements under PAMC 16.64.030 and as permitted by Sb 937. 6 1 1 6 2 2 following multimodal transportation improvements as currently reflected in the Tentative Map: Prior to any on-site grading work, the project applicant shall be required to submit evidence that a Cultural Awareness Training program has been provided to construction personnel. The training shall be facilitated by a qualified archaeologist in collaboration with a Native American representative registered with the Native American Heritage Commission for the City of Palo Alto and that is traditionally and culturally affiliated with the geographic area as described in Public Resources Code Section 21080.3. 7 1 1 6 2 2 11. EVALUATION. The project applicant shall notify the Director of Planning, Native American Monitor, and Archeological Monitor, of any finds during grading or other construction activities. Any historic or prehistoric material identified in the project area during excavation activities shall be evaluated for eligibility for listing in the California Register of Historic Resources as determined by the California Office of Historic Preservation. Data recovery methods may include, but are not limited to, backhoe trenching, shovel test, hand augering, and hand-excavation. The techniques used for data recovery shall follow the protocols identified in the approved treatment plan. Data recovery shall include excavation and exposure of features, field documentation, and recordation. All documentation and recordation shall be submitted to the Northwest Information Center, and the Director of Planning. The qualified archaeologist shall be responsible for submitting all required reports and documentation to the appropriate California Historical Resources Information System (CHRIS) Information Center. 12. TREATMENT PLAN. In the event that any significant cultural materials are encountered during construction, construction within a radius of 100 feet of the find would be halted, the Director of Planning shall be notified, and the on-site qualified archaeologist shall examine the find and make appropriate recommendations regarding the significance of the find and the appropriate treatment of the resource. The qualified archeologist in collaboration with a Native American monitor, registered with the Native American Heritage Commission for the City of Palo Alto and that is traditionally and culturally affiliated with the geographic area as described in Public Resources Code Section 21080.3, shall prepare and implement a treatment plan that reflects permit-level detail pertaining to depths and locations of excavation activities. The treatment plan shall contain, at a minimum: Identification of the scope of work and range of subsurface effects (including location map and development plan), including requirements for preliminary field investigations. Description of the environmental setting (past and present) and the historic/prehistoric background of the parcel (potential range of what might be found). Monitoring schedules and individuals. While coordination will occur jointly, the consulting tribe monitors and archaeological staff shall be notified separately of all scheduling, updates, and field activities to ensure clear and direct communication. Development of research questions and goals to be addressed by the investigation (what is significant vs. what is redundant information). Detailed field strategy to record, recover, or avoid the finds and address research goals. Analytical methods. Report structure and outline of document contents. 8 1 1 6 2 2 Disposition of the artifacts. All cultural materials and artifacts recovered during project-related activities shall remain the property of consulting tribe and shall be returned to the Tribe for final disposition, care, and curation in accordance with Tribal protocols. Security approaches or protocols for finds. In the event that a significant quantity of cultural materials is encountered, the consulting tribe shall require the use of a secure, locked Conex box or equivalent storage unit, to be maintained on-site and managed by the consulting tribe monitor. All associated costs for security measures, including procurement and maintenance of the storage unit, shall be the responsibility of the project applicant/developer. Cultural materials shall remain secured on-site under the consulting tribe oversight until the completion of ground- disturbing activities, at which point the consulting tribe shall assume full possession and responsibility for curation. Appendices: all site records, correspondence, and consultation with Native Americans, etc. The treatment plan shall utilize data recovery methods to reduce impacts on subsurface resources. The treatment plan must be reviewed and approved by the Director of Planning, or the Director’s designee prior to implementation of the plan. 13. HUMAN REMAINS. If human remains are found, the State of California Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. In the event of an unanticipated discovery of human remains, the County Coroner must be notified immediately. If the human remains are determined to be of Native American origin, the Coroner will notify the Native American Heritage Commission, which will determine and notify a most likely descendant (MLD). The MLD has 48 hours from being granted site access to make recommendations for the disposition of the remains. If the MLD does not make recommendations within 48 hours, the landowner shall reinter the remains in an area of the property secure from subsequent disturbance. 14. INDEMNITY. To the extent permitted by law, the Applicant shall indemnify and hold harmless the City, its City Council, its officers, employees and agents (the “indemnified parties”) from and against any claim, action, or proceeding brought by a third party against the indemnified parties and the applicant to attack, set aside or void, any permit or approval authorized hereby for the Project, including (without limitation) reimbursing the City for its actual attorneys’ fees and costs incurred in defense of the litigation. The City may, in its sole discretion, elect to defend any such action with attorneys of its own choice. Public Works Engineering 9 1 1 6 2 2 15. PUBLIC WORKS APPLICATIONS, FORMS, AND DOCUMENTS: Applicant shall be advised that most forms, applications, and informational documents related to Public Works Engineering conditions can be found at the following link: https://www. paloalto.gov/Departments/Public-Works/Engineering-Services/Forms-and-Permits 16. OVERVIEW AND GUIDELINES FOR THE REVIEW OF SUBDIVISION PROJECTS. Developer shall familiarize themselves with the guidelines described in the November 2007 revision of the document titled “Overview and Guidelines for the Review of Subdivision Projects”. Particularly Section II (items 5 through 12) and Section V (items A through C). https://www.paloalto.gov/files/assets/public/planning-amp-development-services/file- migration/current-planning/forms-and-guidelines/overview-and-guidelines-for-the- review-of-subdivision-projects.pdf 17. SUBDIVISION IMPROVEMENT AGREEMENT. The applicant shall execute a Subdivision Improvement Agreement and provide improvement securities (Bonds) for all proposed public improvements. THE AGREEMENT SHALL BE EXECUTED PRIOR TO MAP RECORDATION OR ISSUANCE OF ANY PERMITS FOR CONSTRUCTION, ONSITE AND OFFSITE. ADVISORY -- The applicant shall provide a detailed itemized stamped and signed engineer's estimate for all off-site public improvements which will be reviewed to determine the security amount. 18. FINAL MAP. This project is subject to, and contingent upon the approval of a tentative map and recordation of a Final Map. The submittal, approval and recordation of the Map shall be in accordance with the provisions of the California Subdivision Map Act and Palo Alto Municipal Code Title 21 Subdivision requirements. All existing and proposed property lines, easements, dedications shown on the tentative map are subject to City’s technical review and staff approval during the map process prior to issuance of any construction permits. 19. MAP THIRD-PARTY REVIEW. The City contracts with a third-party surveyor that will review and provide approval of the map’s technical correctness as the City Surveyor, as permitted by the Subdivision Map Act. The Public Works Department will forward a Scope & Fee Letter from the third-party surveyor and the applicant will be responsible for payment of the fee’s indicated therein, which is based on the complexity of the map. 20. STREETWORK PERMIT. The applicant shall obtain a Streetwork Permit from the Department of Public Works for all public improvements. 21. UPGRADE OF EXISTING PUBLIC IMPROVEMENTS. As part of the plan review for improvements within the public right-of-way, any existing improvements to be re-used by the project, which are not to current City standards and are not specifically in these project conditions (such as streetlights, utility covers and lids, etc.), shall be upgraded to current City standards as required by the Director of Public Works and the Director of Utilities. 10 1 1 6 2 2 22. MODIFICATIONS TO EXISTING PUBLIC UTILITIES. The Developer is responsible for any changes or modifications to existing utilities, streets, and public infrastructure within or adjacent to the project site. This includes, but is not limited to, the relocation of utility facilities, conduits, or vaults required due to grade changes in the sidewalk area resulting from the development. The utility design as shown in the Tentative Map is not final. The utility design submitted for the development application (25PLN-00296) shall take precedent. 23. DAMAGE TO EXISTING PUBLIC IMPROVEMENTS. The Developer is responsible for repairing any damage to existing public improvements fronting or adjacent to the project site caused by construction, to the satisfaction of the Public Works Department. 24. EXISTING UTILITY ABANDONMENT AND/OR RELOCATION. The Developer is responsible for researching all existing utility lines to ensure there are no conflicts with the project. Any existing utility lines (public or private) or their appurtenances that conflict with the project or do not serve it must be capped, abandoned, removed, relocated, or disposed of to the satisfaction of the City. 25. GRADING AND EXCAVATION PERMIT. A Grading Permit is required per PAMC Chapter 16.28. The permit application and all applicable documents (see Section H of application) shall be submitted to Public Works Engineering. Add the following note: “THIS GRADING PERMIT WILL ONLY AUTHORIZE GENERAL GRADING AND INSTALLATION OF THE STORM DRAIN SYSTEM. OTHER BUILDING AND UTILITY IMPROVEMENTS ARE SHOWN FOR REFERENCE INFORMATION ONLY AND ARE SUBJECT TO SEPARATE BUILDING PERMIT APPROVAL.” The grading design as shown in the Tentative Map is not final. The grading design submitted for the development application (25PLN-00296) shall take precedent. 26. ROUGH GRADING. Provide a Rough Grading Plan for the work proposed as part of the Grading and Excavation Permit application. The Rough Grading Plans shall including the following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over excavation, stockpile area of material, overall earthwork volumes (cut and fill), temporary shoring for any existing facilities, ramps for access, crane locations (if any), tree protection measures, etc. 27. CIVIL ENGINEER CERTIFICATION. Upon completion of the rough grading work and at the final completion of the work, applicant shall provide an as-graded grading plan prepared by the civil engineer that includes original ground surface elevations, as-graded ground surface elevations, lot drainage patterns and locations and elevations of all surface and subsurface drainage facilities. The civil engineer shall certify that the work was done in accordance with the final approved grading plan. 28. DIRECT CONNECTIONS TO STORM DRAIN SYSTEM. If the project proposes to replace and/or add connections to the City maintained storm drain system, then the applicant 11 1 1 6 2 2 may be responsible for improvements to the system. These improvements may include, but not limited to, upsizing the storm drain facility, replacing or adding City standard catch basins, pipes and manholes. THIS MAY INCLUDE REPLACING BRICK AND MORTAR MANHOLES. The extent of required improvements will be at the public works staff discretion and shall be consistent with Storm Drain Master Plan and Public Works Construction Standards. Any work on the city's storm drain systems requires permits and inspection by Public Works inspectors. 29. CCTV OF STORM DRAIN SYSTEM. Post construction the applicant may be required to provide CCTV inspection of the City’s storm drain facilities to verify that any lines were not broken, cracked or damaged during construction. The video shall be high resolution and done by professional who is familiar with the process and meticulous. A CCTV inspection video is required for new storm drain connection (s) to verify proper connections were made into the City’s system and that no construction material was left behind. Videos of storm drain system may also be required where construction occurred less than 5-ft from the city’s storm drain system. Videos shall be provided from structure to structure, such as manhole to manhole. Contractor may want to conduct their own inspection in advance of construction to verify the existing pipe integrity. If existing damages are located, they shall be reported to Public Works inspectors prior to the start of construction. If not reported, the contractor may be responsible to restore the pipe segment as determined by Public Works prior to final. 30. GEOTECHNICAL ENGINEER STATEMENT. The grading plans shall include the following statement signed and sealed by the Geotechnical Engineer of Record: “THIS PLAN HAS BEEN REVIEWED AND FOUND TO BE IN GENERAL CONFORMANCE WITH THE INTENT AND PURPOSE OF THE GEOTECHNICAL REPORT”. 31. SWPPP. This proposed development will disturb more than one acre of land. Accordingly, the applicant shall apply for coverage under the State Water Resources Control Board’s (SWRCB) NPDES general permit for storm water discharge associated with construction activity. A Notice of Intent (NOI) shall be filed for this project with the SWRCB in order to obtain coverage under the permit. The General Permit requires the applicant to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP). The applicant is required to submit two copies of the NOI and the draft SWPPP to the Public Works Department for review and approval prior to issuance of the building permit. The SWPPP should include both permanent, post-development project design features and temporary measures employed during construction. 32. ENCROACHMENT PERMIT. Prior to any work in the public right-of-way, the applicant shall obtain an encroachment permit from the Public Works Department for any work that encroaches onto the City right-of-way. 33. LOGISTICS PLAN. A construction logistics plan shall be provided addressing all impacts to the public including, at a minimum: work hours, noticing of affected businesses, bus 12 1 1 6 2 2 stop relocations, construction signage, dust control, noise control, storm water pollution prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance, Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may require an encroachment permit. 34. STORMWATER POLLUTION PREVENTION. All improvement plan sets shall include the “Pollution Prevention – It’s Part of the Plan” sheet. 35. C.3 THIRD-PARTY CERTIFICATION. Applicant shall provide certification from a qualified third-party reviewer that the proposed permanent storm water pollution prevention measures comply with the requirements of Provision C.3 and Palo Alto Municipal Code Chapter 16.11. Submit the following: a. Provide a stamped and signed C.3 data form (April 2024 version) from SCVURPPP. https://scvurppp.org/2024/09/19/provision-c-3-data-form-2024/ b. Final stamped and signed letter confirming which documents were reviewed and that the project complies with Provision C.3 and PAMC 16.11. 36. C.3 STORMWATER AGREEMENT. The applicant shall enter into a Stormwater Maintenance Agreement with the City to guarantee the ongoing maintenance of the permanent storm water pollution prevention measures. The City will inspect the treatment measures yearly and charge an inspection fee. The agreement shall be executed by the applicant team prior to building permit final. 37. C.3 FINAL THIRD-PARTY CERTIFICATION PRIOR TO OCCUPANCY. Within 45 days of the installation of the required storm water treatment measures and prior to the issuance of an occupancy permit for the building, the third-party reviewer shall submit to the City a certification verifying that all the permanent storm water pollution prevention measures were installed in accordance with the approved plans. 38. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (STORM DRAIN LOGO). The applicant is required to paint “No Dumping/Flows to Barron Creek” in blue on a white background adjacent to all onsite storm drain inlets. The name of the creek to which the proposed development drains can be obtained from Public Works Engineering. Stencils of the logo are available from the Public Works Environmental Compliance Division, which may be contacted at (650) 329-2598. Include the instruction to paint the logos on the construction grading and drainage plan. 39. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (RECORD DRAWINGS). At the conclusion of the project applicant shall provide digital as-built/record drawings of all improvements constructed in the public right-of-way or easements in which the City owns an interest. 13 1 1 6 2 2 40. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (INDEFINITE ENCROACHMENT PERMIT). An approved indefinite encroachment permit will be required for any private infrastructure constructed in the public right-of-way, easement or on property in which the City holds an interest, but that was not authorized by a building permit. Office of Transportation 41. PLAN SET REVISION REQUIRED PRIOR TO TRANSPORTATION APPROVAL. All items shall be addressed and incorporated into a revised plan set prior to Transportation approval. 42. FIRE ACCESS AND PARKING RESTRICTIONS. The fire truck path of travel shall include a "No Parking" sign. Signs meet the City's Fire Department requirements. 43. PARKING RESTRICTIONS. The curb along Old Trace Road shall be red-striped on both sides of the street to prevent parking within the fire truck path of travel. 44. SIGHT DISTANCE AND VISIBILITY. Sight triangles shall provide clear sight lines in accordance with stopping sight distance requirements in the Highway Design Manual. Landscaping, walls, or any features within sight distance triangles shall be restricted to a maximum height above the roadway surface. Per PAMC 16.24.020(5), fences exceeding four feet in height shall not be located within a sight distance triangle. a. The sight distance triangles shown on C1.2 shall be drawn to scale on the plan set and be prepared and signed by a traffic engineer. 45. BICYCLE FACILITIES. Dedicated bike lanes shown along the Arastradero Road frontage shall meet design standards and maintain a typical width of 5 feet. Green pavement markings are shown in the bicycle conflict zone on Arastradero Road. Per CA MUTCD 2026, green pavement is an optional treatment to alert users of a conflict zone but shall be accompanied by appropriate pavement marking patterns (dotted lines through the driveway). A detail showing dotted extension lines through the driveway apron per CA MUTCD 2026 shall be provided. a. Sharrow markings shall be removed from the plans for Arastradero Road, as no existing sharrows are present on the roadway. 46. PEDESTRIAN FACILITIES. For continuous pedestrian connection, a sidewalk shall be provided along Lots 8 and 9. New sidewalk shown on the project frontage shall conform to meet the City’s minimum standards. 47. DRIVEWAY & ACCESS STANDARDS. The minimum spacing between the two driveways, measured from radius return to radius return, shall be no less than 20 feet per PAMC 12.08.060(9)(A). 48. SIGNAGE AND TRAFFIC CONTROL DEVICES. A one-way sign shall be provided below the 14 1 1 6 2 2 stop sign on the new private street, and one sign shall be provided in the median island for right-turning traffic. All traffic control devices proposed in the public right-of-way (ROW) shall meet CA MUTCD requirements, including size, mounting height, and location. Review and approval shall be obtained as part of the offsite improvement plan. RRFB installation shall comply with CA MUTCD 2026, including any advance line markings or as otherwise required or recommended. A STOP bar shall be provided per CA MUTCD 2026 requirements. Offsite improvements shall be routed to Transportation for review and approval. Electrical Engineering – Utilities Department 49. TRENCHING. The proposed trench shall meet the City of Palo Alto Utilities (CPAU) clearance requirements. 50. ELECTRICAL BOX AND CONDUITS. The electrical boxes and conduit requirements shall be finalized during the building permit application. No load calculations or requested service sizes have been provided as a part of this application but shall be finalized at the time of streamlined housing development application. 51. ELECTRICAL LOAD CALCULATIONS. CPAU scope may change based on estimated load calculations at the time of building permit application. 52. TRANSFORMER CLEARANCE. The proposed transformers shall maintain a minimum clearance of 3 feet on all sides except the front which shall have a clearance of 8 feet. A minimum distance of 10 feet shall be maintained from any proposed windows and doors. 53. EASEMENTS. All electrical easements will be required to be granted to CPAU for CPAU electric utility boxes and conduits per CPAU regulations and standards. 54. STREETLIGHT MAINTENANCE. All privately owned streetlights shall be maintained by the applicant. Water Quality Division – Public Works Department 55. DETENTION GALLERY. The applicant shall clarify if a detention gallery will be required. If required, it shall be included as a part of the C3 Stormwater Treatment Plan. 56. STORMDRAIN CONNECTIONS. Direct connections to the storm drain system is not permitted. The plans shall be revised in accordance with Public Works Engineering standards and addressed at the time of the Streamlined Housing Development Review application. 15 1 1 6 2 2 57. STORMWATER MANAGEMENT PLAN. The proposed Stormwater Management Plan submitted under the Tentative Map application is not final and all stormwater treatment requirements for the project shall be adhered to in compliance with the Bay Area Municipal Regional Stormwater Permit. The Stormwater Management Plan in the development application (25PLN-00296) will take precedent. Water-Gas-Wastewater (WGW) Engineering – Utilities Department 58. PRIOR TO PLANNING ENTITLEMENT APPROVAL. The following comments are required to be addressed prior to Planning entitlement approval: a. A public utility easement for gas service on the private street for the gas main line will be recorded from property line to property line on the street. 59. PRIOR TO BUILDING PERMIT ISSUANCE. The following comments are required to be addressed prior to any future related permit application such as a Building Permit, Excavation and Grading Permit, Certificate of Compliance, Street Work Permit, Encroachment Permit, etc. These comments are provided as a courtesy and are not required to be addressed prior to the Planning entitlement approval: a. The gas main line will be located 5 feet away from the sewer line shown on-site towards the center of the private street. b. The City of Palo Alto Utilities Department CPAU will design the gas main and provide the developer with an invoice for the design work by the City. Payment for the invoice is required before the City starts designing. Provide the WGW reviewer with a contact for the invoice to be sent. i. Schedule a meeting with CPAU reviewer once the estimated gas loads have been determined. CPAU will go over the steps for adding gas mains to the project. 60. PRIOR TO DEMOLITION PERMIT (IF REQUIRED). The applicant shall submit a request to disconnect utility services and remove gas meters. The utilities demo is to be processed within 10 working days after receipt of the request. The demolition permit will be issued by the building inspection division after all utility services and/or meters have been disconnected and removed. For Building Permit: 61. WGW SERVICE CONNECTION APPLICATION. The applicant shall submit a completed water-gas-wastewater service connection application - load sheet for the City of Palo Alto Utilities. The applicant must provide all the information requested for utility service demands (water in fixture units/g.p.m., gas in b.t.u.h, and sewer in fixture units/g.p.d.). The applicant shall provide the existing (prior) loads, the new loads, and the combined/total loads (the new loads plus any existing loads to remain). 16 1 1 6 2 2 62. IMPROVEMENT PLANS FOR UTILITY CONSTRUCTION. The applicant shall submit improvement plans for utility construction. The plans must show the size and location of all underground utilities within the development and the public right of way including meters, backflow preventers, fire service requirements, sewer mains, sewer cleanouts, sewer lift stations, and any other required utilities. Plans for new wastewater laterals and mains need to include new wastewater pipe profiles showing existing potentially conflicting utilities especially storm drain pipes, electric and communication duct banks. Existing duct banks need to be daylighted by potholing to the bottom of the duct bank to verify cross section prior to plan approval and starting lateral installation. Plans for new storm drain mains and laterals need to include profiles showing existing potential conflicts with sewer, water, and gas. 63. AUXILLARY WATER SUPPLY. The applicant must show on the site plan the existence of any auxiliary water supply, (i.e. water well, gray water, recycled water, rain catchment, water storage tank, etc). 64. UPGRADING EXISTING UTILITY MAINS/SERVICES. The applicant shall be responsible for installing and upgrading the existing utility mains and/or services, laterals as necessary to handle anticipated peak loads. This responsibility includes all costs associated with the design and construction for the installation/upgrade of the utility mains and/or services/laterals. 65. RPPA BACKFLOW PREVENTER DEVICE. An approved reduced pressure principle assembly (RPPA backflow preventer device) is required for all existing and new water connections from Palo Alto Utilities to comply with requirements of California administrative code, title 17, sections 7583 through 7605 inclusive. The RPPA shall be installed on the owner's property and directly behind the water meter within 5 feet of the property line. RPPA's for domestic service shall be lead free. Show the location of the RPPA on the plans. a. An approved reduced pressure detector assembly (RPDA backflow preventer device, STD. WD-12A or STD. WD-12B) is required for all existing and new fire water connections from Palo Alto Utilities to comply with requirements of California administrative code, title 17, sections 7583 through 7605 inclusive. The RPDA shall be installed on the owner's property and directly behind the City owned meter, within 5' (feet) of the property line or City Right of Way. 66. APPROVAL OF BACKFLOW PREVENTION DEVICE. All backflow preventer devices shall be approved by the WGW engineering division. Inspection by the city inspector is required for the supply pipe between the meter and the assembly. 67. PAYMENT OF CAPACITY AND CONNECTION FEES. The applicant shall pay the capacity fees and connection fees associated with new utility service/s or added demand on existing services. The approved relocation of services, meters, hydrants, or other facilities will be performed at the cost of the person/entity requesting the relocation. 17 1 1 6 2 2 68. FIRE SYSTEM USAGE. If a new water service line installation for fire system usage is required. Show the location of the new water service on the plans. The applicant shall provide to the engineering department a copy of the plans for fire system including all fire department's requirements. 69. WATER METERS. Each unit or building shall have its own water meter shown on the plans. Each parcel shall have its own water and sewer lateral connection shown on the plans. 70. SEWER LATERAL. A sewer lateral per lot is required. Show the location of the new sewer lateral on the plans. A profile of the sewer lateral is required showing any possible conflicts with storm, electric/communications ductbanks or other utilities. 71. ABANDONMENT OF EXISTING UTILITIES. All existing water, and gas. and wastewater services/laterals that will not be reused shall be abandoned at the main per the latest WGW utilities standards by CPAU. 72. LOCATION OF PROPOSED UTILITY CONNECTIONS. Utility vaults, transformers, utility cabinets, concrete bases, or other structures cannot be placed over existing water, gas, or wastewater mains/services. Maintain 1' horizontal clear separation from the vault/cabinet/concrete base to existing utilities as found in the field. If there is a conflict with existing utilities, Cabinets/vaults/bases shall be relocated from the plan location as needed to meet field conditions. Trees may not be planted within 10 feet of existing water, gas, and wastewater mains/laterals/water services/or meters. New water or wastewater services/laterals/meters may not be installed within 10' of existing trees. Maintain 10' between new trees and new water and wastewater services/laterals/meters. 73. COPY OF FIRE SYSTEM PLAN. The applicant shall provide to the WGW Utility Engineering department a copy of the plans for fire system including all fire department's requirements prior to the actual service installation. 74. PALO ALTO CODE COMPLIANCE. All utility installations shall be in accordance with the City of Palo Alto utility standards for water, gas, & wastewater. SECTION 7. Term of Approval. Tentative Map. All conditions of approval of the Tentative Map shall be fulfilled prior to approval of a Final Map (PAMC Section 21.16.010[c]). Unless a Final Map is filed, and all conditions of approval are fulfilled within a two-year period from the date of Tentative Map approval, the Tentative Map shall expire and all proceedings shall terminate. A request for an extension of time may be granted by the City Council after recommendation of the planning commission, after the written extension request of the subdivider is submitted, prior to the expiration of the Tentative Map approval, or any previous extension granted. Such extension(s) shall be subject to the maximum limitations set forth in the Subdivision Map Act. 18 1 1 6 2 2 // 19 1 1 6 2 2 PLANS AND DRAWINGS REFERENCED: Those plans prepared by Steel Bridge Homes “THE OAKS SUBDIVISION TENTATIVE SUBDIVISION MAP” consisting of eleven pages, dated and submitted May 5, 2026. From:marilynstocker To:Council, City Subject:4103 Old Trace Road Date:Tuesday, May 12, 2026 9:31:21 AM Attachments:Denial request for 4103 Old Trace.docx CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report Request to disapprove the tentative map for the subdivision at 4103 Old Trace Road The proposal to build 9 houses plus 7 jadus at 4103 Old Trace Road will create a dangerous vehicular “bottleneck” at the intersection of Old Trace Road and Arastradero. This intersection is the only exit for the residents of 3 dead end streets: Old Trace Road, Old Trace Court and Mockingbird Lane. It is a busy intersection with poor visibility due to shadows created by shady trees on Arastradero and road curvature, to see cars and e- bikes that travel east at 35 mile an hour or more. The developer claims that the road that bisects the proposed development will give another egress, however that narrow road would be inadequate to accommodate their 32 cars plus the 58 or more from residents of the existing 3 dead end streets (Old Trace Road, Old Trace Court and Mockingbird lane) in an evacuation. The height of the proposed 2 story houses, their fences and plantings that back onto Arastradero will further interfere with visibility. The plan for 9-2 story dwellings, plus adus, plus an internal roadway provides inadequate parking. The excess cars will be forced to park on the narrow streets of Old Trace Road and Mockingbird Lane, decreasing visibility at the intersection of Old Trace Road and Mockingbird Lane. As it is, the curvature of Old Trace Road south of Mockingbird Lane impedes visibility without additional parked cars. We know from past experience, that cars parked on Old Trace Road, and Mockingbird Lane made it unsafe for residents to walk, for emergency vehicles to turn into Mockingbird Lane, for disabled residents to be picked up from their homes, and for children to bike safely. We are not on a bus route that serves Palo Alto, and adjacent towns. This 2 lane section of Arastradero is the main car, bike and walking route for Palo Alto and Los Altos Hills students in the Palo Alto school district, who attend Gunn High School, Fletcher Middle Powered by Mimecast School, and Bowman private school during the week and for 2 synagogues and 2 churches on Saturdays and Sundays. This proposed development faces the large campus on Stanford Industrial Park land, which prior to the pandemic had 4000 VMWare employees, many who used Arastradero linking Foothill Expressway and 280. During peak commuting hours it was difficult for residents of the above mentioned 3 streets, to safely exit or enter Old Trace Road. This campus, now under new ownership is in the process of revitalizing buildings for future increased use. Marilyn Stocker, 880 Mockingbird Bird Lane Request to disapprove the tentative map for the subdivision at 4103 Old Trace Road The proposal to build 9 houses plus 7 jadus at 4103 Old Trace Road will create a dangerous vehicular “bottleneck” at the intersection of Old Trace Road and Arastradero. This intersection is the only exit for the residents of 3 dead end streets: Old Trace Road, Old Trace Court and Mockingbird Lane. It is a busy intersection with poor visibility due to shadows created by shady trees on Arastradero and road curvature, to see cars and e- bikes that travel east at 35 mile an hour or more. The developer claims that the road that bisects the proposed development will give another egress, however that narrow road would be inadequate to accommodate their 32 cars plus the 58 or more from residents of the existing 3 dead end streets (Old Trace Road, Old Trace Court and Mockingbird lane) in an evacuation. The height of the proposed 2 story houses, their fences and plantings that back onto Arastradero will further interfere with visibility. The plan for 9-2 story dwellings, plus adus, plus an internal roadway provides inadequate parking. The excess cars will be forced to park on the narrow streets of Old Trace Road and Mockingbird Lane, decreasing visibility at the intersection of Old Trace Road and Mockingbird Lane. As it is, the curvature of Old Trace Road south of Mockingbird Lane impedes visibility without additional parked cars. We know from past experience, that cars parked on Old Trace Road, and Mockingbird Lane made it unsafe for residents to walk, for emergency vehicles to turn into Mockingbird Lane, for disabled residents to be picked up from their homes, and for children to bike safely. We are not on a bus route that serves Palo Alto, and adjacent towns. This 2 lane section of Arastradero is the main car, bike and walking route for Palo Alto and Los Altos Hills students in the Palo Alto school district, who attend Gunn High School, Fletcher Middle churches on Saturdays and Sundays. This proposed development faces the large campus on Stanford Industrial Park land, which prior to the pandemic had 4000 VMWare employees, many who used Arastradero linking Foothill Expressway and 280. During peak commuting hours it was difficult for residents of the above mentioned 3 streets, to safely exit or enter Old Trace Road. This campus, now under new ownership is in the process of revitalizing buildings for future increased use. Marilyn Stocker, 880 Mockingbird Bird Lane Request to disapprove the tentative map for the subdivision at 4103 Old Trace Road The proposal to build 9 houses plus 7 jadus at 4103 Old Trace Road will create a dangerous vehicular “bottleneck” at the intersection of Old Trace Road and Arastradero. This intersection is the only exit for the residents of 3 dead end streets: Old Trace Road, Old Trace Court and Mockingbird Lane. It is a busy intersection with poor visibility due to shadows created by shady trees on Arastradero and road curvature, to see cars and e- bikes that travel east at 35 mile an hour or more. The developer claims that the road that bisects the proposed development will give another egress, however that narrow road would be inadequate to accommodate their 32 cars plus the 58 or more from residents of the existing 3 dead end streets (Old Trace Road, Old Trace Court and Mockingbird lane) in an evacuation. The height of the proposed 2 story houses, their fences and plantings that back onto Arastradero will further interfere with visibility. The plan for 9-2 story dwellings, plus adus, plus an internal roadway provides inadequate parking. The excess cars will be forced to park on the narrow streets of Old Trace Road and Mockingbird Lane, decreasing visibility at the intersection of Old Trace Road and Mockingbird Lane. As it is, the curvature of Old Trace Road south of Mockingbird Lane impedes visibility without additional parked cars. We know from past experience, that cars parked on Old Trace Road, and Mockingbird Lane made it unsafe for residents to walk, for emergency vehicles to turn into Mockingbird Lane, for disabled residents to be picked up from their homes, and for children to bike safely. We are not on a bus route that serves Palo Alto, and adjacent towns. This 2 lane section of Arastradero is the main car, bike and walking route for Palo Alto and Los Altos Hills students in the Palo Alto school district, who attend Gunn High School, Fletcher Middle School, and Bowman private school during the week and for 2 synagogues and 2 This proposed development faces the large campus on Stanford Industrial Park land, which prior to the pandemic had 4000 VMWare employees, many who used Arastradero linking Foothill Expressway and 280. During peak commuting hours it was difficult for residents of the above mentioned 3 streets, to safely exit or enter Old Trace Road. This campus, now under new ownership is in the process of revitalizing buildings for future increased use. Marilyn Stocker, 880 Mockingbird Bird Lane The intersection of Old Trace Road and Arastradero, the site of the proposed development, is the only exit for the residents of 3 dead end streets: Old Trace Road, Old Trace Court and Mockingbird Lane. It is a busy intersection with poor visibility of on-coming cars and e-bikes that travel east at 35 mile an hour or more. The plan for 9-2 story dwellings, plus adus, plus an internal roadway provides inadequate parking. The excess cars will be forced to park on the narrow streets of Old Trace Road and Mockingbird Lane, decreasing visibility even more. Since there are no sidewalks in the neighborhood, we must walk or run on the street for daily exercise, for visiting our neighbors, for walking our dogs. We know from past experience, that cars parked on Old Trace Road, and Mockingbird Lane made it unsafe for residents to walk, for emergency vehicles to turn into Mockingbird Lane, for disabled residents to be picked up from their homes. We are not on a bus route that serves Palo Alto, and adjacent towns. It takes 20-30 minutes to walk to El Camino to catch a bus. This section of Arastradero is the main car, bike and walking route for Palo Alto and Los Altos Hills students in the Palo Alto school district, who attend Gunn High School, Fletcher Middle School, and Bowman private school during the week and for 2 synagogues and 2 churches on Saturdays and Sundays. This proposed development faces the large campus on Stanford Industrial Park land, which prior to the pandemic had 4000 employees, many who used Arastradero linking Foothill Expressway and 280. During peak commuting hours it was difficult for residents to safely exit or enter Old Trace Road. From:Jeannie Clancy To:Templeton, Cari; Bryna Chang; bryna.chang@gmail.com; To: Comm"r Ji; Allen Akin; To: Chair Akin; To: Comm"r Peterson; Cha, Kelly; Stone, Greer; Stone, Greer; Veenker, Vicki; Veenker, Vicki; Reckdahl, Keith; bgh@matteoni.com; Armer, Jennifer; Council, City; Lauing, Ed; Lu, George; Burt, Patrick; Lythcott-Haims, Julie; Reckdahl, Keith Subject:Request to Pull Item [25PLN-00298] (4103 Old Trace Road Tentative Map) from Consent Calendar Date:Friday, May 15, 2026 3:37:26 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear Mayor and Members of the Palo Alto City Council, I am writing to formally request that the Consent Calendar item regarding 4103 Old Trace Road [25PLN-00298] (Tentative Map for a 9-lot subdivision, 9 single-family residences, and 7 JADUs) be pulled and placed on the regular agenda on May 18, 2026 for full public discussion and a separate vote. Substantial new information and unresolved critical safety issues emerged during the Planning and Transportation Commission (PTC) meeting that demand council scrutiny and public transparency: 1. At the PTC meeting, the City Planner explicitly acknowledged that fire danger was not evaluated beyond the immediate boundaries of the project lot. This lot is located within city and county fire protection management areas. Neighborhood fire mitigation is required annually. The project site sits at the intersection of Old Trace Road, which dead- ends at a 21-acre park, and Arastradero Road, a critical east-west evacuation route. Multiplying neighborhood density at this specific bottleneck creates an extreme safety hazard. 2. The applicant is seeking a waiver to reduce the required 32-foot- wide private road to just 20 feet. This substandard road will prevent emergency vehicles from turning into the development. To fix this, the PTC recommended painting "no parking" red curbs on Old Trace Road near the development entrance. Eliminating on street parking spaces near the development will force cars to be parked further up Old Trace Road which prevents emergency access to my house and puts more people on a street without pedestrian infrastructure like sidewalks. City Council must deny a waiver preventing emergency access. 3. A mandatory 53-foot special setback applies to 200 feet of the proposed development property line to protect the environmentally sensitive areas around Barron Creek and its tributaries. A similar setback is found on Oakhill Avenue just to the east of this lot. This is not a zoning setback and all the neighboring properties comply with it. This This message needs your attention This is a personal email address. This is their first mail to some recipients. Mark Safe Report critical environmental protection was never discussed, analyzed, or fully explained to the public. 4. Pursuant to PAMC Chapter 18.10, the RE district allows a baseline maximum of two primary units per parcel, not 7. Applying maximum bonus density multipliers to this base zoning establishes an absolute, legally unyielding limit of three primary units for this parcel. The RE district is explicitly codified to protect and dictate "very low-density" residential use. It is legally distinct from standard single-family residential zones (R-1) or any sub-categories thereof, which are governed by a completely separate chapter of the municipal code. Because three Councilmembers must agree to pull an item from the Consent Calendar, I urge you to act in the interest of neighborhood safety, environmental protection, and due process by moving this item to the regular agenda. Thank you for your time and your dedication to the safety of Palo Alto residents. Sincerely, Jeannie Clancy 4146 Old Trace Road -- Jeannie Clancy 970-261-5527 From:James Lloyd To:Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki; Council, City Cc:Clerk, City; City Attorney; City Mgr; PlannerOnDuty Subject:public comment re item 12 for the 5/18/26 Council meeting Date:Thursday, May 14, 2026 11:36:21 AM Attachments:Palo Alto - 4103 Old Trace Road - HAA Letter - CC.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Palo Alto City Council, The California Housing Defense Fund (CalHDF) submits the attached public comment in support of item 12 for the 5/18/26 Council meeting, the proposed 16-unit housing development project at 4103 Old Trace Road, which includes one unit affordable to moderate- income households. Sincerely, James M. Lloyd Director of Planning and Investigations California Housing Defense Fund james@calhdf.org CalHDF is grant & donation funded Donate today - https://calhdf.org/donate/ May 14, 2026 City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 Re: Proposed Housing Development Project at 4103 Old Trace Road By email: Pat.Burt@PaloAlto.gov; Ed.Lauing@PaloAlto.gov; George.Lu@PaloAlto.gov; Julie.LythcottHaims@PaloAlto.gov; Keith.Reckdahl@PaloAlto.gov; Greer.Stone@PaloAlto.gov; Vicki.Veenker@PaloAlto.gov; city.council@PaloAlto.gov Cc: city.clerk@CityofPaloAlto.org; city.attorney@cityofpaloalto.org; CityMgr@cityofpaloalto.org; Planner@CityofPaloAlto.org; Dear Palo Alto City Council, The California Housing Defense Fund (CalHDF) submits this letter to remind the City of its obligation to abide by all relevant state laws when evaluating the proposed 16-unit housing development project at 4103 Old Trace Road, which includes one unit affordable to moderate-income households. These laws include the Housing Accountability Act (HAA), the Density Bonus Law (DBL), and AB 130. The HAA provides the project legal protections. It requires approval of zoning and general plan compliant housing development projects unless findings can be made regarding specific, objective, written health and safety hazards. (Gov. Code, § 65589.5, subds. (d), (j).) The HAA also bars cities from imposing conditions on the approval of such projects that would render the project infeasible (id. at subd. (d)) or reduce the project’s density (id. at subd. (j)) unless, again, such written findings are made. As a development with at least two-thirds of its area devoted to residential uses, the project falls within the HAA’s ambit, and it complies with local zoning code and the City’s general plan. Increased density, concessions, and waivers that a project is entitled to under the DBL (Gov. Code, § 65915) do not render the project noncompliant with the zoning code or general plan, for purposes of the HAA (Gov. Code, § 65589.5, subd. (j)(3)). The HAA’s protections therefore apply, and the City may not reject the project except based on health and safety standards, as outlined above. Furthermore, if the City rejects the project or impairs its feasibility, it must conduct “a 2201 Broadway, PH1, Oakland, CA 94612 www.calhdf.org thorough analysis of the economic, social, and environmental effects of the action.” (Id. at subd. (b).) CalHDF also writes to emphasize that the DBL offers the proposed development certain protections. The City must respect these protections. In addition to granting the increase in residential units allowed by the DBL, the City must not deny the project the proposed waivers and concessions with respect to lot size, setback, street width, and site depth. If the City wishes to deny requested waivers, Government Code section 65915, subdivision (e)(1) requires findings that the waivers would have a specific, adverse impact upon health or safety, and for which there is no feasible method to satisfactorily mitigate or avoid the specific adverse impact. If the City wishes to deny requested concessions, Government Code section 65915, subdivision (d)(1) requires findings that the concessions would not result in identifiable and actual cost reductions, that the concessions would have a specific, adverse impact on public health or safety, or that the concessions are contrary to state or federal law. The City, if it makes any such findings, bears the burden of proof. (Gov. Code, § 65915, subd. (d)(4).) Of note, the DBL specifically allows for a reduction in required accessory parking in addition to the allowable waivers and concessions. (Id. at subd. (p).) Additionally, the California Court of Appeal has ruled that when an applicant has requested one or more waivers and/or concessions pursuant to the DBL, the City “may not apply any development standard that would physically preclude construction of that project as designed, even if the building includes ‘amenities’ beyond the bare minimum of building components.” (Bankers Hill 150 v. City of San Diego (2022) 74 Cal.App.5th 755, 775.) Furthermore, the project is eligible for a statutory exemption from environmental review under AB 130 (Pub. Res. Code, § 21080.66). Caselaw from the California Court of Appeal affirms that local governments err, and may be sued, when they improperly refuse to grant a project a CEQA exemption or streamlined CEQA review to which it is entitled. (Hilltop Group, Inc. v. County of San Diego (2024) 99 Cal.App.5th 890, 911.) As you are well aware, California remains in the throes of a statewide crisis-level housing shortage. New housing such as this is a public benefit: it will provide badly-needed affordable housing; it will bring new customers to local businesses; it will increase the city’s tax revenue; and it will reduce displacement of existing residents by reducing competition for existing housing. It will also help cut down on transportation-related greenhouse gas emissions by providing housing in denser, more urban areas, as opposed to farther-ﬂung regions in the state (and out of state). While no one project will solve the statewide housing crisis, the proposed development is a step in the right direction. CalHDF urges the City to approve it, consistent with its obligations under state law. CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for increased access to housing for Californians at all income levels, including low-income households. You may learn more about CalHDF at www.calhdf.org. 2 of 3 Sincerely, Dylan Casey CalHDF Executive Director James M. Lloyd CalHDF Director of Planning and Investigations 3 of 3 From:Heather Clancy To:Council, City Cc:Kandikuppa, Nishita Subject:4103 Old Trace Rd. Date:Wednesday, May 13, 2026 6:11:37 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. i Dear council members, As a resident of Old Trace Rd. I am concerned about the development plan being proposed. This is not simply a matter of housing production; it is a matter of maintaining the integrity of adopted planning policies and ensuring fair and lawful treatment of existing residents. The subdivision map 25PLN-00298 is not compliant with California Government Code Section 66474(b)(d)(g). Help me understand why the applicant has not been required to correct their map. -The City has clearly confirmed that the project site is located within the RE zoning district, which is intentionally designed and maintained as a low-density, large-lot residential area with a base unit density of 2. -The land use policy for this area policy L1.2 states that undeveloped land west of Foothill Expressway is retained as open space, with allowances made for very low intensity development consistent with the open space character of the area. -The site has a recorded special set back of 53’ along Arastradero. For 50 years this has been enforced by the city. The proposed subdivision creates parcels that are noncompliant with RE zoning. Approval of such a map would directly conflict with state law, which mandates consistency between subdivision design and local land use regulations. If lot sizes violate RE zoning → map must be denied. The committee members expressed opinions at the meeting held on March 5 and April 29, 2026, that “This development as proposed is incompatible with this location”. Yet no substantial modifications have been required to bring the subdivision of this 1 acre lot into alignment with applicable laws and policies. The county and City has both the authority and the obligation to enforce its zoning code and uphold the planning framework that residents rely upon. Even under California’s pro-housing laws:-The City is not required to approve a project that rewrites its zoning code through a subdivision map.-If a project fails objective standards or legal prerequisites, the City can deny, condition, or require redesign.-State housing laws (SB 330, HAA, Density Bonus, SB 130) all share a core rule: They protect compliant projects—notnoncompliant projects. Please consider denying the application as is. This lot can provide much needed housing without changing the landscape per se. Stuffing This message needs your attention This is a personal email address. This is their first mail to some recipients. Mark Safe Report Powered by Mimecast this lot will create potentially 44 very frustrated residents in this peaceful neighborhood. The applicant brings 1 small unit for moderate income housing. This parcel can provide 1 unit moderate income housing with a simple legal lot split. Thank you for your time and consideration of this matter, Heather Clancy From:E Pirrotta To:Council, City Subject:Comments on 4103 Old Trace Road development plan Date:Wednesday, May 13, 2026 10:30:30 AM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. To the Palo Alto City Council I urge you to approve the tentative map to allow the subdivision of 4103 Old Trace Road. The proposed development is an excellent use of the land and is a good solution for improving affordable housing options. Please ensure that the plan for these proposed homes maintain deed-restricted household income levels. Thank you Elizabeth Pirrotta 4103 Old Trace Road Subdivision: Tentative Map Presenter: Nishita Kandikuppa, Associate Planner May 18, 2026 www.paloalto.gov PROJECT OVERVIEW Zoning & Existing Improvements •Residential Estate (RE) •Vacant lot Scope of Work •Subdivide vacant 1.02-acre lot into: •9 residential lots •1 private street for access (Lot 10 – Street Parcel) •Separate Planning Entitlement for proposed housing: •Nine single-family residence (w/ one BMR unit/lot) •Seven Junior Accessory Dwelling Units (JADUs) TENTATIVE MAP *The area shaded in red represents the proposed 10-foot drainage easement along Arastradero Road VEHICULAR ACCESS & CIRCULATION •Private Street: •Vehicular right-of-way: 20 feet •Total right-of-way (including sidewalks and landscaped median): 30.5 feet •Through street with two -way traffic •Red-painted curbs designated for fire/emergency vehicle/refuse truck access •No parking will be permitted on private street •No right-turn access into private street for east-bound traffic on Arastradero Road •Reduced curb radius design on the west side of the Arastradero Road entrance REQUESTED WAIVERS AND CONCESSIONS •Reduce minimum lot size in the RE zoning district from 6,000 sq ft to allow lot sizes ranging from 1,570 sq. ft. to 6,907 sq. ft. •Reduce special setback along Arastradero Road from 53 feet to 9 feet 6 inches on Lot 5, and 15 feet for Lots 6 and 9 •Reduce the minimum width of private street from 32 feet to 20 feet •Reduce minimum site depth from 100 feet to 59 feet The applicant is eligible for one concession which will be formally requested at the time of the Streamlined Housing Development Review application. KEY CONSIDERATIONS •The project may not be denied based on inconsistency with the Zoning Ordinance or Comprehensive Plan land use. •City may deny or reduce the density of the project only on the basis of a specific, adverse impact on public health or safety that cannot be mitigated. •Under State Density Bonus Law, the applicant may request waiver of applicable standards that would physically prevent the project from being built at the permitted density. •AB 130 exempts infill housing projects from CEQA and sets strict timelines for City review and decision. RECOMMENDED MOTION Staff recommends the City Council to take the following actions: •Consider the project exempt from the California Environmental Quality Act (CEQA) in accordance with Assembly Bill (AB 130) •Approve the Tentative Map application pursuant to findings and subject to conditions of approval set forth in Attachment A (Draft Record of Land Use Action) of the supplementary report NISHITA KANDIKUPPA Associate Planner nishita.kandikuppa@paloalto.gov (650) 838-2806 THE OAKS Steel Bridge Homes Palo Alto, LP 4 1 0 3 O L D T R A C E R O A D , P A L O A L T O 25P LN -00296. 25P LN -00298 [ PROJECT RENDERING OR SITE AERIAL ] P R O J E C T O V E R V I E W 9 Single -Family Residences 7 Junior ADUs (JADUs) 16 Total Dwelling Units 1.02 Acres (Vacant Site) P R O J E C T D E T A I L S Location: 4103 Old Trace Road, Esther Clarks Park Low-Density Residential Project in close proximity to excellent public schools Self-Contained: Private Road connecting Old Trace Rd to Arastradero Rd as well as Old Trace; no need or reason to travel into existing neighborhood [ SITE PLAN / LOCATION MAP ] TH E O AK S · 410 3 O L D TR A CE R OA D , P A LO A L TO · P LA N NIN G A N D TR A NS P OR TA TIO N C O M MIS S IO N · A P RIL 29 , 2026 C O M M U N I TY O U T R E A C H Steel Bridge Homes Palo Alto, LP 4 1 0 3 O L D T R A C E R O A D , P A L O A L T O 25P LN -00296. 25P LN -00298 •Two voluntary meetings with all interested residents in 2025 •Invitation to review plans •Invitation to discuss potential voluntary upgrades on Old Trace Road after ARB hearing (neighbors refused) •Redesign of project after ARB to incorporate more driveways for parking, two -car garages for each unit P R O J E C T O V E R V I E W HOUSING ACCOUNTABILITY ACT & STATE DENSITY BONUS LAW PROTECTED PROJECT A P P R O V A L R E Q U I R E S : Written, Objective and Verifiable Standards not speculation or worry, fear of what additional housing will do to existing home values Limited Ability to Deny or Condition Project, e.g. Health & Safety Risks that cannot be mitigated and that are supported by written, objective and verifiable standards “Safety Risks” are not inchoate “traffic” issues or fire risks to residents who live on substandard streets in the hills of Palo Alto or Los Altos well above the proposed development. Waivers must be granted upon request to facilitate the project as designed by the Developer at the density permitted by law TH E O AK S · 410 3 O L D TR A CE R OA D , P A LO A L TO · C ITY C O UN C IL · M A Y 1 8, 20 26 Voluntary and Responsive Safety Improvements over Existing Conditions . PEDESTRIAN SAFETY New Sidewalk on Old Trace Road + intersection ramp upgrades Added in direct response to community concerns about existing conditions, with planned upgrades to the intersection sidewalk ramps to improve accessibility. PARKING Secondary Access to Arastradero Second access route from Old Trace Road Added right turn on Arastradero creates two means to access Arastradero and limits the need to use the crossing for both left and right turns. EMERGENCY ACCESS Red Curb Striping for Fire Access Painted curb to prevent overflow parking Red curb striping will be added along Old Trace Road opposite the site to keep the curb clear and guarantee fire trucks have full, unobstructed access into the project and for residents near project frontage TH E O AK S · 410 3 O L D TR A CE R OA D , P A LO A L TO · C ITY C O UN C IL · M A Y 1 8, 20 26 Thank You D E V E L O P E R Steel Bridge Homes Palo Alto, LP A P P L I C A T I O N 25PLN -00296 A D D R E S S 4103 Old Trace Road Palo Alto, CA TH E O AK S · 410 3 O L D TR A CE R OA D , P A LO A L TO · C ITY C O UN C IL · M A Y 1 8, 20 26