HomeMy WebLinkAbout2026-08-26 Planning & Transportation Commission Agenda PacketPLANNING AND TRANSPORTATION COMMISSION
Regular Meeting
Wednesday, August 26, 2026
Council Chambers & Hybrid
6:00 PM
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Meeting ID: 916 4155 9499 Phone: 1(669)900-6833
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Listed times are estimates only and are subject to change at any time, including while the
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IN-PERSON PUBLIC COMMENT
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comments will be heard at the beginning of the agenda and remote comments will be heard at the end of the agenda.
CITY OFFICIAL REPORTS
1.Director's Report, Meeting Schedule, and Assignments
ACTION ITEMS
Public Comment is Permitted. Applicants/Appellant Teams: Fifteen (15) minutes, plus three (3) minutes rebuttal. All others:
Three (3) minutes per speaker.
2.Recommendation to the City Council on an Ordinance Amending Chapter 18.20 (Office,
Research, and Manufacturing (MOR, ROLM, RP and GM) Districts) of Title 18 (Zoning) of
the Palo Alto Municipal Code to Clarify that Multiple-Family Residential Uses in the
ROLM(E) Zone District May Be Conditionally Permitted; CEQA Status: Exempt pursuant to
CEQA Guidelines Section 15061(b)(3).
6:15 PM – 6:45 PM
STUDY SESSION
Public Comment is Permitted. Three (3) minutes per speaker.
3.Study Session on South of Forest Area (SOFA) Coordinated Area Plan Objective Design
Standard Approach
6:45 PM – 7:45 PM
COMMISSIONER QUESTIONS, COMMENTS, ANNOUNCEMENTS OR FUTURE MEETINGS AND
AGENDAS
Members of the public may not speak to the item(s).
VIRTUAL PUBLIC COMMENT
Members of the public may speak to any item NOT on the agenda. 1-3 minutes depending on number of speakers. In-person
comments will be heard at the beginning of the agenda and remote comments will be heard at the end of the agenda.
ADJOURNMENT
OTHER INFORMATION
The materials below are provided for informational purposes, not for action or discussion during this meeting’s agenda. Written
public comments may be submitted in advance and will be provided to the Commission and availible for public inspection on the
City’s website three days before the meeting.
A.Public Comment
PUBLIC COMMENT INSTRUCTIONS
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CLICK HERE TO JOIN Meeting ID: 916 4155 9499 Phone:1-669-900-6833
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Item No. 1. Page 1 of 2
Planning & Transportation Commission
Staff Report
From: Planning and Development Services Director
Lead Department: Planning and Development Services
Meeting Date: August 26, 2026
Report #: 2608-6647
TITLE
Director's Report, Meeting Schedule, and Assignments
RECOMMENDATION
Staff recommends that the Planning and Transportation Commission (PTC) review and
comment as appropriate.
BACKGROUND
This document includes the following items:
Upcoming PTC Agenda Items
PTC Meeting Schedule
PTC Representative to City Council (Rotational Assignments)
Commissioners are encouraged to contact Samuel Tavera (Samuel.Tavera@PaloAlto.gov) to
notify staff of any planned absences one month in advance, if possible, to ensure the
availability of a PTC quorum.
PTC Representative to City Council is a rotational assignment where the designated
commissioner represents the PTC’s affirmative and dissenting perspectives to Council
for quasijudicial and legislative matters. Representatives are encouraged to review the City
Council agendas (https://www.cityofpaloalto.org/City-Hall/City-Council/Council-Agendas-
Minutes) for the months of their respective assignments to verify if attendance is needed or
contact staff.
Prior PTC meetings are available online at https://midpenmedia.org/category/government/city-
of-palo-alto/boards-and-commissions/planning-and-transportation-commission.
UPCOMING PTC ITEMS
September 9, 2026
Item 1
Item 1 Staff Report
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Item No. 1. Page 2 of 2
Accessory Dwelling Unit (ADU) Ordinance
ATTACHMENTS
Attachment A: 2026 PTC Schedule & Assignments
AUTHOR/TITLE:
Jennifer Armer, Assistant Director
Item 1
Item 1 Staff Report
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Planning & Transportation Commission
2026 Meeting Schedule
1
2
3
1
1
2026 Schedule
Meeting Dates Time Location Status Planned Absences
1/14/2026 6:00 PM Hybrid Regular
1/28/2026 6:00 PM Hybrid Cancelled
2/11/2026 6:00 PM Hybrid Regular James
2/25/2026 6:00 PM Hybrid Regular Chang
3/11/2026 6:00 PM Hybrid Special James, Ji
3/25/2026 6:00 PM Hybrid Regular
4/8/2026 6:00 PM Hybrid Regular James, Templeton
4/29/2026 6:00 PM Hybrid Regular
5/13/2026 6:00 PM Hybrid Regular Hechtman
5/27/2026 6:00 PM Hybrid Regular
6/10/2026 6:00 PM Hybrid Regular Hechtman
6/24/2026 6:00 PM Hybrid Cancelled Chang
7/8/2026 6:00 PM Hybrid Regular James
7/29/2026 6:00 PM Hybrid Cancelled
8/12/2026 6:00 PM Hybrid Regular
8/26/2026 6:00 PM Hybrid Regular Templeton
9/9/2026 6:00 PM Hybrid Regular
9/30/2026 6:00 PM Hybrid Regular
10/14/2026 6:00 PM Hybrid Regular
10/28/2026 6:00 PM Hybrid Regular
11/11/2026 6:00 PM Hybrid Cancelled
11/18/2026 6:00 PM Hybrid Special Templeton
11/25/2026 6:00 PM Hybrid Cancelled
12/9/2026 6:00 PM Hybrid Regular
12/30/2026 6:00 PM Hybrid Cancelled
2026 Assignments - Council Representation (primary/backup)
January February March April May June
Bryna Chang Allen Akin Bart Hechtman Kevin Ji Todd James Forest Peterson
Todd James Forest Peterson Cari Templeton Bryna Chang Allen Akin Bart Hechtman
July August September October November December
Council Cari Templeton Bryna Chang Allen Akin Bart Hechtman Kevin Ji
Summer Break Kevin Ji Todd James TBD Cari Templeton Bryna Chang
Item 1
Attachment A - 2026 PTC
Schedule & Assignments
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Item No. 2. Page 1 of 6
Planning & Transportation Commission
Staff Report
From: Planning and Development Services Director
Lead Department: Planning and Development Services
Meeting Date: August 26, 2026
Report #: 2607-6589
TITLE
Recommendation to the City Council on an Ordinance Amending Chapter 18.20 (Office,
Research, and Manufacturing (MOR, ROLM, RP and GM) Districts) of Title 18 (Zoning) of the
Palo Alto Municipal Code to Clarify that Multiple-Family Residential Uses in the ROLM(E) Zone
District May Be Conditionally Permitted; CEQA Status: Exempt pursuant to CEQA Guidelines
Section 15061(b)(3).
RECOMMENDATION
Staff recommends that the Planning and Transportation Commission (PTC) take the following
action:
1. Recommend that City Council adopt the draft Ordinance (Attachment A) amending Palo
Alto Municipal Code (PAMC) Section 18.20.030, Table 1, footnote (1), to clarify that
Multiple-Family uses are permitted with a Conditional Use Permit (CUP) in the ROLM(E)
zone.
EXECUTIVE SUMMARY
PAMC Chapter 18.20 contains two provisions that may be interpreted inconsistently. The Land
Use Table in Section 18.20.030 (Land Uses) lists “Multiple-Family” uses within the combined
ROLM/ROLM(E) column (Research, Office, and Limited Manufacturing District and Embarcadero
Subdistrict) as conditionally permitted with footnote (1). This footnote limits the ability to
establish Multiple-Family uses with a CUP to the GM/ROLM Housing Element Focus Area
(Figure 1 below) adjacent to the Bayshore Freeway and generally bounded by East Charleston
Road and Loma Verde Avenue. As shown in Attachment B, which is a map of all ROLM(E) zoned
parcels in the City, because there are no sites designated ROLM(E) within this Focus Area, this
footnote suggests that Multiple-Family uses are actually prohibited in the ROLM(E) subdistrict.
This is inconsistent with language in Section 18.20.040 (Site Development Standards), which
states that “multi-family development in the ROLM(E) zoning district shall be permitted subject
Item 2
Item 2 Staff Report
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Item No. 2. Page 2 of 6
to the provisions [regarding proximity to hazardous materials], approval of a conditional use
permit, and compliance with the development standards prescribed for the RM-20 zoning
district.”
PROJECT DESCRIPTION
Table 1
Industrial/Manufacturing District Land Uses
MOR
RESIDENTIAL USES
,
,
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Item 2 Staff Report
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Item No. 2. Page 3 of 6
prohibited to the extent permissible by law., For ROLM(E) zoned properties, conditionally
permitted regardless of location. subject to CUP.
BACKGROUND
ANALYSIS
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Item 2 Staff Report
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Item No. 2. Page 4 of 6
are concerns that additional development on nearby private properties could affect habitat,
hydrology, views, access, and the broader environmental character of the area if it is not
appropriately planned and designed.
PTC Review and Next Steps
Item 2
Item 2 Staff Report
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Item No. 2. Page 5 of 6
unchanged, but that PAMC Section 18.20.040(b)(5) be amended to clarify that residential uses
are prohibited in the ROLM(E). Following the PTC’s recommendation, the ordinance would be
forwarded to City Council for consideration and final action.
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ALTERNATIVE ACTIONS
ATTACHMENTS
Item 2
Item 2 Staff Report
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Item No. 2. Page 6 of 6
Report Author & Contact Information PTC1 Liaison & Contact Information
Joey Dinh, Senior Planner Jennifer Armer, Assistant Director
(650) 838-2865 (650) 329-2191
Joey.Dinh@palalto.gov Jennifer.Armer@PaloAlto.gov
1 Emails can be sent directly to the ARB using the following address: arb@paloalto.gov
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Item 2 Staff Report
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ATTACHMENT A
*NOT YET APPROVED*
1
0160206_20280813_ay16
Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Amending Chapter 18.20 (Office,
Research, and Manufacturing (MOR, ROLM, RP and GM) of Title 18 (Zoning) of the
Palo Alto Municipal Code to Clarify the Conditional Use Permit Requirement for
Multiple-Family Residential Uses in the ROLM Zone District and ROLM(E)
Subdistrict
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Section 18.20.030 (Land Uses) of Chapter 18.20 (Office, Research, and
Manufacturing Districts) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read
as follows, with deletions shown strikeout, additions underlined, and portions omitted but
unchanged indicated by bracketed ellipses:
18.20.030 Land Uses
(a) Permitted and Conditionally Permitted Land Uses
Table 1 lists the land uses permitted or conditionally permitted in the industrial and
manufacturing districts.
Table 1
Industrial/Manufacturing District Land Uses
[P = Permitted Use CUP = Conditional Use Permit Required]
Notes:
(1) For ROLM and GM zoned properties, conditionally permitted only when located within
the GM/ROLM Housing Element Focus Area, aAdjacent to Bayshore Freeway and generally
bounded by East Charleston Road and Loma Verde Avenue (see Figure 1), and otherwise
MOR ROLM
ROLM(E)
RP
RP(5) GM Subject to regulations
in Chapter:
[…] […] […] […] […] […]
Multiple-Family CUP CUP(1) P (2) CUP(1)
18.14.020,
18.14.040(b)(5),
18.42.200
[…] […] […] […] […] […]
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Attachment A - Draft
Ordinance Amending PAMC
Section 18.20.030, Table 1
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2
prohibited to the extent permitted by law. For ROLM(E) zoned properties, conditionally
permitted regardless of location subject to CUP.
SECTION 2. The Council finds that the adoption of this Ordinance is exempt from the
provisions of the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines
Section 15061(b)(3) because the Ordinance clarifies that multiple-family residential uses may
be considered in the ROLM(E) district through the existing Conditional Use Permit process
established in Section 18.20.040(b)(5). The Ordinance does not approve a specific development
project, modify the applicable development standards, or eliminate discretionary review. As
such, it can be seen with certainty that the proposed action will not have the potential for
causing a significant effect on the environment.
SECTION 3. This ordinance shall be effective on the thirty-first date after the date of
its adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
Assistant City Attorney City Manager
____________________________
Director of Planning and
Development Services
Item 2
Attachment A - Draft
Ordinance Amending PAMC
Section 18.20.030, Table 1
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Item 2
Attachment B - Map of
ROLM(E) Zoned Parcels
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Item No. 3. Page 1 of 5
Planning & Transportation Commission
Staff Report
From: Planning and Development Services Director
Lead Department: Planning and Development Services
Meeting Date: August 26, 2026
Report #: 2606-6513
TITLE
Study Session on South of Forest Area (SOFA) Coordinated Area Plan Objective Design Standard
Approach
RECOMMENDATION
Staff recommends the Planning and Transportation Commission (PTC) review the South of
Forest Area (SOFA) Coordinated Area Plans — Recommended Approach Options for Objective
Design Standards (Attachment A) and provide feedback on the recommended approaches
presented in this staff report.
EXECUTIVE SUMMARY
The City of Palo Alto’s adopted 2023-2031 Housing Element includes Program 3.7, which
requires development of objective design standards in the SOFA Coordinated Area Plan (CAP)
areas. The South of Forest Area (SOFA) Coordinated Area Plans — Recommended Approach
Options for Objective Design Standards memo (Attachment A) presents various approaches to
developing objective standards for the SOFA area, along with analysis, recommendations, and
questions requiring further discussion. This study session is an opportunity for the PTC and
public to review this memo and provide feedback on the various approaches to developing
SOFA objective design standards, including review procedures and regulatory vehicles for the
new objective design standards.
PROJECT DESCRIPTION
The South of Forest Area (SOFA) Objective Design Standards project aims to implement Housing
Element Program 3.7, which calls for the City to “develop Objective Design Standards for the
SOFA Area to accommodate future residential development at higher densities.”1 These
1 The 2023-2031 Housing Element is available online: https://www.paloalto.gov/files/assets/public/v/1/planning-
amp-development-services/housing-element/housing-element_2023_2031/palo-alto-housing-element.pdf
Item 3
Item 3 Staff Report
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Item No. 3. Page 2 of 5
objective standards will apply to qualifying housing development projects that otherwise would
be exempt from non-objective standards per State laws, while minimizing the changes made to
the existing SOFA CAPs. The project team has evaluated the adopted development regulations
in the SOFA CAP 1 and 2, and considered various approaches to developing objective standards
in the SOFA area based on the existing regulations in the SOFA CAP. The SOFA recommended
approach options memo (Attachment A) presents these various approaches to developing
objective standards for the SOFA area, along with analysis, recommendations, and questions
requiring further discussion.
BACKGROUND
South of Forest Area Comprehensive Area Plans
Forest Avenue to the north;
Addison Avenue to the south;
Mid-block between Kipling and Cowper to the east; and
Ramona Street to the west, including a small mid-block section on the west side of
Ramona Street.
Forest Avenue on the north;
Addison Avenue on the south;
Alma Street on the west; and
Ramona Street on the east, excluding the small mid-block section on the west side of
Ramona Street that was included in Phase 1.
Housing Element Program 3.7
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Item No. 3. Page 3 of 5
In order to address the lack of development in the SOFA area in recent years, Program 3.7 is
intended to streamline development in the SOFA CAP; in part by simplifying SOFA’s existing
development regulations and process, which are complex and not easily accessible.
Additionally, the existing SOFA design guidelines are largely subjective and follow a
discretionary process, making review of projects more time consuming and involved. Under
State housing laws passed since the adoption of SOFA 1 and 2, local agencies may no longer
enforce non-objective design standards on most housing development projects; therefore, the
existing SOFA design guidelines cannot be used to condition or deny qualifying housing
projects. Accordingly, Housing Element Program 3.7 intends to resolve these gaps by creating
objective design standards for the SOFA CAP to create a streamlined ministerial review process
and facilitate development within the area plan boundaries. The Housing Element
implementation program timeline includes a deadline of December 31, 2026.
ANALYSIS
Design Review Processes
Track 1, Full Discretionary ARB Review
Track 2, Streamlined Housing Development Review
Track 3, Ministerial/By-right Review
Recommendation: The project team’s recommendation is to align SOFA with the City’s existing
three-track framework, keep the existing SOFA design guidelines for discretionary review, and
use the new SOFA objective design standards for streamlined and ministerial review. This would
make SOFA consistent with citywide review processes and would avoid a confusing and overly
complicated SOFA-specific procedural system. Furthermore, it preserves a substantive design-
review framework for discretionary projects, requires no amendment to the guidelines
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Item 3 Staff Report
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Item No. 3. Page 4 of 5
themselves, and minimizes changes to the existing SOFA CAP, which was developed through a
community-driven process.
Regulatory Vehicles for the New Standards and How to Update the Plans
Option A: Create new appendices containing the objective design standards and adding
these to both SOFA CAP documents.
Option B: Create new SOFA objective design standards to be adopted as a permanent
provision of the Municipal Code, as a new standalone chapter of Title 18 (similar in
structure to Chapter 18.24).
Recommendation: The project team recommends Option B, a new stand-alone chapter in Title
18, as the implementing vehicle for SOFA objective design standards. Codifying the new SOFA
objective design standards in Title 18 produces the most durable, legally clear, and practically
accessible regulatory product. It is also straightforward to adopt, avoids SOFA CAP
amendments, and may enable future updates/incorporation of SOFA development standards if
needed.
Outdated References and State Law Conflicts
FISCAL/RESOURCE IMPACT
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Item No. 3. Page 5 of 5
This project is currently funded for up to $94,050 through the General Fund FY 2026 Adopted
Budget. At this time, the project team expects this work can be accommodated within the
existing scope and resources, including the approved professional services agreement with
Aaron Welch Planning.
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
AUTHOR/TITLE:
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Attachment A: South of Forest Area (SOFA) Coordinated Area Plans — Recommended Approach
Options for Objective Design Standards
Purpose
This memo presents the key structural decisions required to create objective design standards
(ODS) for the SOFA 1 and SOFA 2 Coordinated Area Plans and provides analysis of the
options for each.
Based on background research, the kickoff meeting, and team discussions, the project team
has reached preliminary alignment on several of these decisions and developed
recommendations. This memo presents these recommendations, poses alternative approaches
for consideration, and identifies issues that require resolution prior to proceeding with
developing objective standards.
Background
The SOFA 1 (2000) and SOFA 2 (2003) Coordinated Area Plans contain several distinct types
of regulatory content relevant to this project:
Review procedures (Chapter IV of SOFA 1; Chapter VI of SOFA 2): the processes
governing how projects are reviewed and approved, including review triggers, permits,
and exceptions, discretionary Architectural Review Board (ARB)/Historic Resources
Board (HRB) review, and historic demolition review, with associated findings. These
procedures are entirely discretionary and predate the streamlined and ministerial review
pathways now required by State law.
Development standards (Section 1.0 of each designation in SOFA 1; Chapter V of
SOFA 2): quantitative, zoning-type standards for height, FAR, setbacks, lot coverage,
parking, and density. These are already objective in form, for the most part. The plans
also contain public right-of-way standards. This project is not scoped to revise SOFA's
development standards; how they are incorporated under the recommended approach is
addressed in Section 2.
Design guidelines (Section 2.0 of each designation in SOFA 1; Chapter IV of SOFA 2;):
qualitative guidance used in discretionary ARB/HRB review. These provisions are almost
entirely subjective (compatibility of style, massing, and materials relative to existing
neighborhood character) and cannot lawfully be applied to qualifying housing projects
under current State law.
With the expansion of State housing laws, local agencies may no longer enforce non-objective
design standards for housing development projects. When considering Senate Bill (SB) 35/SB
423 (ministerial review) and/or the Housing Accountability Act (HAA), the practical effect is that
the existing SOFA design guidelines cannot be used to condition or deny qualifying housing
projects. Housing Element Program 3.7 directs the City to resolve this gap by creating objective
design standards that support streamlined/ministerial review.
This memo addresses these three core subject areas for the SOFA ODS project: (1) review
procedures, (2) what document will contain the new SOFA standards and how the existing plan
documents will be updated, and (3) how to handle outdated references and State law conflicts in
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 23
the existing plans. Each section identifies the key decision points and the team’s preliminary
recommendations.
Section 1: Design Review Process
1.1 SOFA Plan Review Processes and Inconsistencies with the Citywide Framework
Citywide Review Framework
●Track 1 — Full Discretionary ARB Review (PAMC 18.77.070): Applicability: New
multifamily (3+ units) that cannot comply with applicable objective design standards or
any non-residential project ≥5,000 sq ft. Process: ARB holds a public hearing and makes
a recommendation; the Planning Director issues written decision appealable to City
Council. Review Criteria: Six affirmative findings required including aesthetic quality,
contextual compatibility, and consistency with applicable plans and design guidelines.
●Track 2 — Streamlined Housing Development Review (PAMC 18.77.073):
Applicability: Multifamily and residential mixed-use projects complying with all applicable
objective standards under Chapter 18.24, where the Housing Accountability Act limits
City discretion. Process: The Director may refer the project to ARB for one study
session; Director issues decision directly. Appeals go to City Council. Review Criteria:
Objective standards.
●Track 3 — Ministerial/By-Right Review (PAMC 18.77.074): Applicability: Projects
qualifying under SB 35, Assembly Bill (AB) 2162, or other use-by-right State law
provisions. Process: Staff review with decision issued by the Director; the Director may
refer the project to ARB for informal review. Review Criteria: No discretionary findings,
no CEQA review. City checks applicable objective criteria and issues or denies the
permit.
SOFA Review Framework
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Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
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The table below identifies the key differences between SOFA 1, SOFA 2, and citywide
processes, along with what changes would occur by bringing SOFA into alignment with the
City’s current review procedures.
Table 1. Review Process Comparison
Topic SOFA 1 SOFA 2 Citywide (PAMC)What changes under
alignment
Coordinated
Development
Permit (CDP)
CDP required under
PAMC Ch. 19.10 before
any alteration,
demolition, or
construction; issued only
on a finding of
consistency with the
CAP (§19.10.060).
CDP required under
PAMC Ch. 19.10 before
any alteration, demolition,
or construction; issued
only on a finding of
consistency with the CAP
(§19.10.060).
Projects follow the
applicable review
process plus standard
zoning/building permits
and CDP, if applicable.
PAMC Chapter 19.10 should
be updated to clarify that
simply a finding of consistency
is required rather than a
separate permit.
Available
review
pathways
Discretionary
Architectural Review
only. No streamlined or
ministerial track.
Discretionary Architectural
Review only. No
streamlined or ministerial
track.
Track 1 (full ARB
discretionary), Track 2
(streamlined/ODS-
based), Track 3
(ministerial/by-right).
Eligible projects within SOFA
that meet ODS can utilize
streamlined and ministerial
review pathways, per State
law.
Historic
resource
review
Historic resources
reviewed under the
Historic Preservation
Ordinance (PAMC Ch.
16.49); but all non-SFR
new construction also
runs through the
combined ARB/HRB
review regardless of
historic status. HRB
recommends to decision
body per Ch. 16.49.
Maintains its own SOFA 2
Historic Resource List and
Potential Historic
Resource List; HRB
reviews against SOFA
Chapter IV requirements
and design guidelines plus
the Secretary of the
Interior’s Standards; Sites
on the Potential SOFA 2
resources list require a
historic study;
Plan contains a separate
demolition permit
procedure and findings
(§6.050).
Ch. 16.49: ARB review
with referral to HRB for
historic/significant
structures (non-SFR);
HRB reviews
SFR/duplex directly
(voluntary); staff may
approve minor
alterations. Drawn from
the Palo Alto Historic
Resources Inventory.
SOFA 1 historic review already
follows Ch. 16.49. HRB review
would only be required for
historic resources. Incorporate
SOFA 2’s historic resource list
into the Citywide Historic
Resources List. Remove
SOFA 2’s potentially eligible
historic sites list, per prior City
Council action. Keep SOFA 2
specific historic protections
(demolition permit/delays).
SFR / Two-Family Uses
SFR / Two-
Family
Review Body
+ Process
Planning staff review
against DHS Standards
and Compatibility
Guidelines; notice to
owners within 150 ft.
Somewhat unclear due to
outdated references, but
appears to follow the
typical citywide Individual
Review Process.
Administrative review
using Two-Story SFR
ODS, or discretionary
Individual Review using
the Single Family
Individual Review
Guidelines. Planning
staff is the reviewing
body.
SFR / Two-
Family
Decision-
maker
Staff or Director (in the
case of appeals)
Director Director
Exceptions /
deviations
Minor exceptions: ZA for
SFR/duplex
In R-2 district, only
variances or home
improvement exceptions
per §18.12.120.
Variances or home
improvement
exceptions per
§18.12.120.
Only SOFA 1 process
changes, since SOFA 2 follows
citywide process.
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 25
Topic SOFA 1 SOFA 2 Citywide (PAMC)What changes under
alignment
Appeals 10-day appeal to
Director. Director’s final
decision non-
appealable.
Director’s Hearing can be
requested. Appeals to City
Council.
Director’s Hearing can
be requested. Appeals
to City Council.
Only SOFA 1 process
changes, since SOFA 2 follows
citywide process. Director
decision appealable to City
Council.
All Other Uses
Review Body Both ARB and HRB
review of all projects
(historic or not);
recommendation to
Director for decision.
Also applies to
AMF/DHS development
in the PAMF block.
ARB review and
recommendation; HRB
review required for sites on
the SOFA 2 Historic
Resource list.
Track 1 Discretionary:
ARB review (public
hearing and
recommendation)
Track 2 Streamlined:
Staff review. Director
may refer to ARB for
informal review.
Track 3 Ministerial:
Staff review. Director
may refer to ARB for
informal review.
HRB review only for
historic resources.
Removes the SOFA 1
ARB/HRB review model for all
projects. HRB review is limited
to historic-resource projects
(Ch. 16.49).
Decision-
maker
Director (on ARB/HRB
recommendation); PTC
also involved for major
exceptions.
Director Director Consistent – no change
Review
Criteria /
Findings
Consistency with the
CAP’s policies,
programs, regulations,
and design guidelines.
Consistency with the
CAP’s policies, programs,
regulations, and design
guidelines.
Track 1: ARB findings
(§18.76.020) and
context-based design
criteria, including
consistency with
applicable plans.
Tracks 2/3: Applicable
objective standards
(Ch. 18.24).
SOFA guidelines are retained
for Track 1 discretionary
review; new SOFA ODS are
applied to Track 2 or Track 3.
Exceptions /
deviations
Minor exceptions:
Folded into ARB review/
recommendation to
Director.
Major exceptions:
Require both ARB and
PTC recommendations
to the Director.
Only variances in rare
circumstances (PAMC Ch.
18.90) or Design
Enhancement Exceptions
allowed, limited to
setbacks and parking lot
design based on ARB
review/approval
Variance or Design
Enhancement
Exception process (per
§18.76.050) as part of
architectural review.
Track 2/3: If a project
deviates from ODS, it is
routed to full
discretionary review
(Track 1).
Removes separate SOFA-only
exception procedures where
they duplicate or conflict with
citywide review. SOFA 1’s
separate PTC step for major
exceptions is removed. SOFA
2’s narrow exception set is
replaced by citywide Design
Enhancement Exceptions
process within ARB review.
Appeals Appeal to City Council
following citywide
process
Appeal to City Council Appeal to City Council.Consistent – no change
1.2 Recommended Review Framework: Align SOFA with the Citywide Three-Track
Process
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 26
The project team’s recommendation is to align SOFA with the City’s existing three-track
framework, keep the SOFA design guidelines for discretionary review, and use the new SOFA
objective design standards (ODS) only for streamlined and ministerial pathways. Similar to other
Coordinated Area Plans (CAPs) in the City, projects would need to meet a finding of
consistency with the CAP, per PAMC Chapter 19.10; however, Chapter 19.10 would be updated
to clarify that simply a finding of consistency is required rather than a separate CDP permit. This
would make SOFA project review consistent with the way projects are reviewed citywide, and
would avoid a confusing and overly complicated SOFA-specific procedural system for the same
types of projects. Furthermore, it preserves a substantive design review framework for
discretionary projects, requires no amendment to the guidelines themselves, and is consistent
with the approach to minimize changes to the existing SOFA plans, which was developed
through a community-driven process.
Track 1 — Full discretionary review: Would apply to projects that are not eligible for
streamlined or ministerial review, including projects that elect not to comply with one or
more applicable ODS. The existing SOFA design guidelines and SOFA 2 compatibility
requirements would continue to apply as discretionary review criteria in Track 1. Single
and two-family projects would use the City’s current Individual Review process.
Track 2 — Streamlined housing development review: Would apply to qualifying
housing projects that comply with all applicable objective standards, including the new
SOFA ODS. The review would follow the City’s existing streamlined process, including
the advisory ARB role allowed under the citywide framework. Single and two-family
projects would be eligible for administrative review if using the Two-Story SFR Objective
Design Standards.
Track 3 — Ministerial/by-right review: Would apply to projects qualifying for ministerial
approval under State law. Review would be limited to the new SOFA objective standards
and applicable State-law eligibility criteria.
1.3 Historic Resource Review
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 27
substantive demolition bar SOFA 2 now provides, and only voluntary review for historic single-
family and two-family homes rather than the mandatory HRB review under SOFA. To bring
SOFA historic review into alignment with citywide processes, while keeping SOFA-specific
protections, the team recommends the following:
Fold SOFA 2’s separate Historic Resource List into the citywide Historic Resources
Inventory to ensure that they do not get missed. A reference to the citywide list will be
added to SOFA.
Remove SOFA 2’s Potential Historic Resources List aligning with November 12, 2024,
City Council Informational Report on staff determination to remove "Potentially Eligible"
Historic Status From Parcel Reports.
Keep SOFA 2’s stronger historic demolition permit and procedures.
Section 2: Regulatory Vehicle for Standards and How to Update the Plans
2.1 Location of the New SOFA ODS
Option A: New Appendix to the SOFA CAP Documents
Procedural Clarity
High. ODS are adopted as part of the governing CAP documents. The amendment is additive
and limited in scope.
Pros
Keeps ODS within the SOFA plan structure while leaving guidelines untouched
Keeps SOFA development and design standards in the same document
Amendment is additive and narrow
Cons
Applicants must navigate two separate plan documents (SOFA 1 and SOFA 2), each
with a new appendix, plus the body of each plan for guidelines and development
standards, and the zoning code for other applicable standards.
The ODS would be duplicated in both SOFA 1 and SOFA 2 appendices. Any future
revisions would require updates to both plans/appendices rather than one consolidated
set of ODS.
The ODS will likely reference specific citywide ODS for certain topics, which would
require applicants to bounce between the SOFA CAP and zoning code for all applicable
standards.
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 28
Usability
Moderate. ODS are within the plan documents, which is intuitive, but the appendices may be
difficult for applicants to locate. Most permit applicants may expect design standards in the
Municipal Code, given their location for other plan districts/plan areas. As mentioned above, if
citywide design standards in the municipal code are referenced for certain topics (per
recommendations in Section 2.3 below), users will need to bounce around between the SOFA
CAP and code to find all applicable standards.
Option A produces the objective standards required by Housing Element Program 3.7 and takes
the approach of appending to, rather than revising, the SOFA plans. It only partially advances
usability and simplification goals, however, because applicants must still consult multiple
documents to identify all applicable standards. This is a reasonable option if the City is open to
a narrow plan amendment, but it may not be as user-friendly as Option B, and results in
duplicative standards located in both SOFA 1 and SOFA 2 appendices.
The new SOFA ODS are adopted as a permanent provision of the Municipal Code, in the form
of a new standalone chapter of Title 18 searchable in the Municipal Code library, and governed
by the same amendment process as other Title 18 provisions. The structure of the ODS code
section for the new SOFA district chapter would be similar to Chapter 18.24 (citywide ODS).
The SOFA plan documents would require a cross-reference note directing applicants to the new
code section.
High. A new Title 18 chapter establishing ODS for the SOFA area is straightforward to adopt
and unambiguous in its applicability. It is also consistent with how the City recently created a
new code section to implement the North Ventura Coordinated Area Plan (NVCAP) standards
(Chapter 18.29).
Fully codified in the Municipal Code, searchable, permanent, and governed by the same
processes as all other zoning standards.
Provides one consolidated set of ODS for both SOFA 1 and 2, without duplication.
A new standalone SOFA chapter can house both the objective design standards and the
SOFA-specific review procedure provisions.
Allows the SOFA development standards to be codified alongside the design standards,
so applicants for streamlined and ministerial projects can find all applicable standards in
a single code chapter.
Limits SOFA plan amendments.
Consistent with how the City adopted the NVCAP standards in a new zoning chapter, so
the structure is already familiar to staff, decision-makers, and applicants.
Reduces, but does not remove, the need to look in more than one place for standards.
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 29
High. Title 18 is the first place most people look for objective development and design
standards, and provides an opportunity to keep all SOFA objective development and design
standards all in one place. The main risk is applicants starting with the SOFA plan documents
and missing applicable code sections; a prominently placed cross-reference in both SOFA plans
is essential.
Project Objectives Consistency
Summary Recommendation: The project team recommends Option B — a new standalone Title 18
chapter containing all objective development and design standards for both SOFA 1 and 2.
2.2 Development Standards
Discretionary review (Track 1): Applicants work from the SOFA plans, which contain
the development standards and design guidelines that govern discretionary review.
Streamlined and ministerial review (Tracks 2 and 3): Applicants work from the new
Title 18 chapter, which contains all the SOFA objective development and design
standards in one location.
2.3 Topic-by-Topic Design Standard Recommendations
Reference: Topics where Chapter 18.24 or other citywide standards already provide
adequate, objective standards applicable to the SOFA context (e.g., lighting standards,
bird friendly design standards). The new chapter would incorporate these by direct
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 30
reference (“See §18.24.0XX”) without replicating the text. This avoids duplication and
reduces future maintenance issues.
New/Adapt: Topics that Chapter 18.24 or other citywide standards do not address or
that are specific to the SOFA area (e.g., paseos, roof treatments, window trim/recess) or
where Chapter 18.24 has a relevant standard but it needs calibration for the SOFA
context.
Duplication should be minimized where PAMC Chapter 18.24 or citywide standards already
cover a topic clearly, both for administrative efficiency and to avoid inconsistency. Where SOFA-
specific standards genuinely differ, a new provision is appropriate. Note that some subjective
guidelines cannot be converted into clear and objective standards. In these instances, we could
keep them as guidelines in the new SOFA ODS. They would be encouraged but not required for
streamlined/ministerial projects. The table below provides topic-by-topic recommendations with
references.
Table 2. Topic-by-Topic Recommendations
Legend — Recommendation:
Reference Ch. 18.24 (citywide Objective Design Standards), Two-Story SFR ODS, or other citywide standards
(e.g. parking, landscaping, signs)
Create new SOFA-specific standard (not covered, or materially different)
Retain in SOFA plan as guideline only
Topic SOFA
reference(s)Recommendation Citywide reference /
mechanism Notes
A. Building Design
Architectural
compatibility /
neighborhood
context
SOFA 1
(Architecture; Design
Character); SOFA 2
§4.010 and §4.030(b)
Guideline Only
(no objective
equivalent)
Most of these guidelines cannot be converted
into clear and objective standards. Consider
whether to keep some of these as guidelines
(encouraged, but not required) in the ODS.
Compatibility
with Historic
Structures
SOFA 1 (6.14d);
SOFA 2 §4.010(b)
(Compatibility with
historic structures
and other existing
structures)
Guideline Only
(no objective
equivalent)
Most of these guidelines cannot be converted
into clear and objective standards. Consider
whether to keep some of these as guidelines
(encouraged, but not required) in the ODS.
Building
orientation &
setbacks
SOFA 1 (Setbacks)Reference Ch.
18.24
§18.24.040 (Building
Orientation & Setbacks)
Orientation covered by §18.24.040. Numeric
setbacks are development standards that will
remain as-is.
Massing and
Façade
Design
SOFA 1 (Massing/
building articulation);
SOFA 2 §4.030(b);
§4.030(f) (Massing/
building articulation)
Reference Ch.
18.24 / Adapt as
needed
§18.24.050 (Building
Massing); §18.24.060
(Façade Design)
Covered by the Citywide ODS. Reference
these or adapt several to the SOFA context, if
needed.
Height
Transitions/
Daylight
Planes
SOFA 1 (Daylight
Plane) and §5.6
(Special height and
setback
requirements); SOFA
2 §5.030(a)
SOFA-specific
standard /
adapt as
needed
SOFA has daylight plane development
standards that are different from the citywide
standards in Ch 18.24, along with guidelines.
Recommend keeping as is. Create or adapt
existing ODS as needed for any stepback
design guidelines in SOFA.
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 31
Topic SOFA
reference(s)Recommendation Citywide reference /
mechanism Notes
Roof Form SOFA 1 (Roof
Forms/Designs)
Guideline Only /
Reference SFR
ODS
§18.40.260 (Visual
Screening and
Landscaping)
Roof form compatibility requirements cannot
be made objective but could be kept as a
guideline (encouraged, not required). Roof
equipment screening guideline is covered by
PAMC 18.40.260 (Visual Screening and
Landscaping). Reference the Two-Story SFR
ODS for roof pitch for SFR/duplex
development.
Entrances SOFA 1 (Entrances);
SOFA 2 §4.030(d)
Reference Ch.
18.24 / Create
SOFA-specific
standard for
SFR
§18.24.030 (Site
Access); §18.24.040
(Building Orientation and
Setbacks); §18.24.070
(Residential Entries)
Covered by the citywide ODS, which has more
specific requirements than SOFA. Two-story
SFR ODS only has one standard for porch
compatibility. Reference this for SFR in SOFA,
or create several single-family specific
standards.
Paseos /
pedestrian
passages
SOFA 2 §4.030(c)Guideline Only
(no objective
equivalent)
Paseos are encouraged in SOFA 2. Keep as a
guideline. Reference Public Works paseo
standards, if available.
Materials SOFA 2 §4.030(b)Reference Ch.
18.24
§18.24.090 (Materials)Only referenced in SOFA 1 in terms of
architectural compatibility. Covered by
§18.24.090 (Materials).
Windows/
Fenestration
SOFA 1 (Windows)Reference SFR
ODS/ Create
new SOFA
standards for
MFR
Two-Story SFR ODS
(A15)
Use Two-Story SFR ODS for single-family
uses (A15: Window to Wall Detailing); Create
new ODS to require window trim or recess for
MFR.
Ground Floor
Non-
Residential
Design
SOFA 1 (6.14);
SOFA 2 §4.030(o)
and §4.010(b)
Reference Ch.
18.24
§18.24.040.b.5 (Front
Yard Setback Character);
§18.24.060.b.5
(Storefront/Retail Ground
Floors); §18.24.060.b.6
(Other Non-residential
Ground Floors)
Covered by the citywide ODS, which has
extensive requirements for nonresidential
ground floor design (setback character,
transparency, ground floor height, awnings,
etc.).
Ground Floor
Residential
Design
SOFA 2 §4.030(o)Reference Ch.
18.24
§18.24.040.b.4 (Ground
Floor Residential Unit);
§18.24.040.b.5 (Front
Yard Setback Character);
§18.24.060 (Façade
Design); §18.24.070
(Residential Entries)
Covered by the citywide ODS, which has
extensive requirements for residential ground
floor design (setback character, finished floor
height, frontage types, etc.).
Sustainability
/ green
building
NA Reference Ch.
18.24
§18.24.100
(Sustainability and Green
Building Design); Ch
16.14 (citywide Green
Building ordinance)
Not covered in SOFA. Reference §18.24.100
and the citywide green building ordinance.
Topic SOFA
reference(s)Recommendation Citywide reference /
mechanism Notes
B. Site Design
Driveways
and Vehicle
Access
SOFA 1 (Driveways);
SOFA 2 §4.030(g)
Reference
citywide
standards/
Create SOFA
specific
standards as
needed
§18.24.030 (Site
Access); §18.54.070
(Parking Design Tables
and Figures)
Vehicle-access location is covered by
§18.24.030 (Site Access); driveway
dimensions via citywide parking and driveway
design standards. Retain/create SOFA-
specific standards for setback of driveways
and maximum number of curb cuts, hollywood
style driveways, and driveway landscaping for
single-family residential.
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 32
Topic SOFA
reference(s)Recommendation Citywide reference /
mechanism Notes
Parking /
Garages
SOFA 1 (Garages)Two-Story SFR
ODS for single-
family uses; Ch.
18.24 for MFR
Two-Story SFR ODS
(A6 - A9); §18.24.060
(Parking/Loading/Utilitie
s); §18.54.020 (Vehicle
Parking Facilities);
§18.54.040
(Landscaping of Parking
Areas)
Use the Two-Story SFR ODS for single-family
uses to the extent feasible, which has
standards for garage placement, width, and
door dimensions, or create SOFA-specific
garage standards for SFR in SOFA as
needed. Multi-family is covered by the
Parking/Loading/Utilities standard in
§18.24.060. SOFA 2 also has some surface
parking guidelines that could be covered by
citywide standards in Ch. 18.54.
Bicycle
Facilities
SOFA 2 §4.030(m)Reference other
citywide
standards
§18.52.040 and
18.54.060
Covered by citywide bicycle-parking
requirements.
Fences,
Walls, and
Screening
SOFA 1 (Fences and
Walls); SOFA 2
§4.030(h)
Reference other
citywide
standards/
Create new
SOFA standards
Ch. 16.24 (Fences);
§18.40.260 (Visual
Screening and
Landscaping)
Use citywide fence/wall and visual-screening
standards. Create SOFA-specific standard for
a 5 ft planting strip along fences/walls, with
trees planted 20 ft on center.
Public Open
Space
SOFA 1 (4.9(e)
Landscaping); SOFA
2 §4.030(q)
Create new
SOFA standards
Ch. 18.24 does not contain any public open
space standards. Create new SOFA standards
for public open space (pocket parks/plazas).
Private Open
Space
SOFA 1 (Common
Open Space); SOFA
2 §4.030(i); §
5.050(k/l)
Reference Ch.
18.24 / Create
new SOFA
standards
§18.24.080 (Open
Space)
Private common open space is covered by
citywide ODS. SOFA does not contain
personal private open space standards or
guidelines. SOFA 2 does not contain
private/common open space requirements.
Discuss the need to add private/common open
space requirements for SOFA 2. Consider
adding minimum dimensions for
balconies/patios based on SOFA open space
requirements.
Private
Landscaping
SOFA 1
(Landscaping); SOFA
2 §4.030(i)
Reference other
citywide
standards
§18.40.130
(Landscaping);
§18.40.260 (Visual
Screening and
Landscaping); Ch. 12.32
(Water Use
Regulations)
§18.40.130 (Landscaping) and §18.40.260
(Visual Screening and Landscaping) contain
landscaping requirements for SFR/two-family
homes, and landscape screening
requirements.
Lighting SOFA 1 (Lighting);
SOFA 2 §4.030(j)
Reference other
citywide
standards
§18.40.250 (Lighting)Use citywide lighting standards in §18.40.250
(Lighting).
Signage SOFA 1 (Signage);
SOFA 2 §4.030(k)
Reference other
citywide
standards
Ch. 16.20 (Signs)Use the citywide sign ordinance (Ch. 16.20).
Public Art SOFA 2 §4.030(k)Reference other
citywide
standards
Chapter 16.61 (Public
Art for Private
Developments)
SOFA 2 has a guideline that encourages
public art. Keep this as a guideline
(encouraged, not required), and also reference
the citywide public art ordinance.
Refuse,
Service and
Loading
Areas
SOFA 1 (6.14); SOFA
2 §4.030(p)
Reference Ch.
18.24 / other
citywide
standards
§18.24.030 (Site
Access); §18.40.240
(Refuse Disposal
Areas); 18.40.260
(Visual Screening and
Landscaping)
Location/screening of service and loading
areas is covered by §18.24.030 (Site Access).
Storage and equipment screening is covered
citywide in §18.40.260 (Visual Screening and
Landscaping). Use the citywide refuse
standards in §18.40.240 (Refuse Disposal
Areas).
Noise SOFA 1 (6.14); SOFA
2 §4.030r; SOFA 2
§5.050 (RT Districts -
Performance
Standards); §5.120(a)
Reference other
citywide
standards
Citywide Noise
Ordinance (Ch. 9.10);
§18.42.190 (Noise and
Vibration); §18.42.040
SOFA 1 and 2 contain noise guidelines for
non-residential/auto uses, and noise mitigation
in particular on Alma St. Use the citywide
standards in the noise ordinance, 18.42.190
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 33
Topic SOFA
reference(s)Recommendation Citywide reference /
mechanism Notes
(Late Night Uses and
Activities)
(Noise and Vibration), and §18.42.040 (Late
Night Uses and Activities). Alma
Street/transportation-noise provisions are
covered by (and in some cases exceeded by)
the California Building Code (§1206.4) and the
General Plan Noise element, and have
therefore been superseded.
Other
performance
standards
(fumes/odors,
etc.)
SOFA 1 (6.14); SOFA
2 §5.050 (RT Districts
- Performance
Standards)
Reference other
citywide
standards
§18.40.270 (Air Quality);
§18.42.040 (Late Night
Uses and Activities)
SOFA 1 contains guidelines for reducing
noise, odors, etc. for auto/commercial uses.
SOFA 2 contains performance standards for
noise, odors, and other visual impacts, which
are called "standards" but do contain some
subjective language. Remove subjective
language to make these objective.
Alternatively, reference citywide standards in
§18.40.270 (Air Quality) and §18.42.040 (Late
Night Uses and Activities).
Section 3: Outdated References and State Law Conflicts
Both SOFA plans contain provisions that are outdated or superseded — by State law or by
changes in the City’s regulatory framework since adoption. This section outlines those conflicts
and provides preliminary recommendations for how we might resolve them.
3.1 Consistency with State Law
SB 79 (effective July 1, 2026)
The majority of the SOFA plan areas fall within one-half mile of the Downtown Palo Alto Caltrain
station, a Tier 1 TOD stop under SB 79. For qualifying projects, SB 79 establishes minimum
density, height, and residential FAR floors of 100-120 du/ac, 65-75 feet, and 3.0-3.5 FAR
respectively, depending on distance. These minimums substantially exceed the SOFA plans’
current development standards. SB 79’s upzoning provisions are generally effective July 1,
2026, unless the City first adopts an HCD-approved implementing ordinance or local TOD
alternative plan. The City adopted a temporary ordinance that will allow roughly 50% of the
otherwise-applicable SB 79 density through July 1, 2027. The new ODS will be drafted so that it
does not, alone or in combination with other standards, prevent a qualifying project from
achieving SB 79 minimums, and the team will calibrate massing standards to anticipated
building envelopes at both the interim (50%) and full (100%) density scenarios. The citywide
ODS in PAMC Chapter 18.24 do not currently address high-rise/tower development. staff will be
updating Chapter 18.24 to address SB 79 development.
State Density Bonus Law
Design standards that would effectively prevent a project from achieving its density bonus
entitlements are legally vulnerable. Under State Density Bonus Law, an applicant may request
waivers or reductions of development standards, including height, FAR, and setbacks, that
would physically preclude construction at the permitted density or with the granted concessions.
The ODS will therefore be drafted to anticipate the massing that could result when SOFA's
standards are waived or modified for bonus projects, so that the objective standards remain
workable under those scenarios. Nonetheless, it remains possible for a Density Bonus applicant
to waive the ODS as well.
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 34
SB 330 / HAA
SB 330 (the Housing Crisis Act) and the Housing Accountability Act limit the City to applying
objective, quantifiable standards in effect when a preliminary or complete application is
submitted, and constrain its ability to deny, reduce the density of, or attach non-objective
conditions to a qualifying housing project. The new ODS must therefore be objective to be
enforceable on the streamlined (Track 2) and ministerial (Track 3) pathways. SOFA’s subjective
design guidelines and compatibility findings may be applied only through Track 1 discretionary
review. SOFA 2’s exclusivity language (“the procedures in this Chapter VI are the only
procedures applicable in SOFA 2”) is a priority item for resolution, given its potential to be read
as obstructing the State-mandated streamlined and ministerial pathways.
Although revising development standards is outside this project's scope, some of SOFA's
existing standards, notably its restrictive FAR limits and daylight standards, may warrant review,
since a standard that would preclude a qualifying housing project from reaching its allowed
density may be subject to waiver under state law.
The SOFA plans’ second-unit provisions predate current State ADU Law, which was recodified
in 2024 from former Government Code § 65852.2 into §§ 66310–66342. ADUs and junior ADUs
must be approved ministerially, without discretionary or design review, a hearing, or a CDP, and
once an application is complete the City has 60 days to act or the permit is deemed approved.
Local standards that conflict with State ADU law cannot be imposed. As a result, SOFA 1’s
second-unit standards (e.g. 750 sf size limitation) and any discretionary review cannot be
enforced where they conflict with State law. The City must allow at least an 850-square-foot
ADU (1,000 sf for two or more bedrooms), may require no more than four-foot side and rear
setbacks, and may not require parking for ADUs within one-half mile walking distance of transit,
which covers SOFA.
AB 2097 prohibits the City from imposing or enforcing minimum automobile parking
requirements on residential or commercial development within one-half mile of a major transit
stop. The Downtown Palo Alto Caltrain station brings essentially the entire SOFA area within
that radius, so SOFA’s minimum parking ratios are unenforceable. The City may still apply
objective standards to the design and location of parking that is voluntarily provided and may set
parking maximums.
SB 9’s ministerial urban lot split and two-unit provisions apply only to parcels in single-family
residential zones. Most SOFA parcels are zoned for two-family, multifamily, or mixed use, so SB
9 has limited applicability. However, SOFA 1’s Detached Houses on Small Lots (DHS) district
qualifies as single-family for SB 9 purposes and therefore would need to allow SB 9 units.
In addition to regulations that conflict with, or have been superseded by State law, as outlined
above, the SOFA plans also contain outdated references and regulations. Examples include:
SOFA 1 Mixed-Use 1 (MU-1) and Mixed-Use 2 (MU-2) districts and their associated
standards and guidelines, which were superseded when SOFA 2 was adopted and
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 35
rezoned that area. Staff has confirmed these districts are no longer applicable, so their
standards and guidelines will not be carried into the new code chapter.
The SOFA 1 Chapter IV and SOFA 2 Chapter VI review procedures, which will be
superseded once the new chapter establishes the review process
Inclusionary provisions that have been updated (e.g. BMR inclusionary percentage)
References to the pre-2017 Comprehensive Plan and former Housing Element program
references
References and map showing RM-15 district, which is now the RM-20 district
Cross-references to sections of Title 18 (and related code) that no longer exist or have
been renumbered (e.g. former Chapter 16.48 for architectural review)
SOFA 2 appendices containing outdated Title 18 chapters
References to City departments or staff titles that have changed (e.g., "Department of
Planning and Community Environment")
Outdated definitions
Summary Recommendation: The project team will identify conflicts and outdated content for review
and resolution. At a minimum, add language in the new Title 18 chapter, or in a short note appended
to each plan, providing that where a SOFA provision conflicts with State law, State law prevails.
Summary Recommendations
The project team’s summary of recommendations is as follows.
Review Process: Align the SOFA review process with the citywide three-track
framework. Replace the SOFA 1 Chapter IV and SOFA 2 Chapter VI procedures with
cross-references to the citywide PAMC tracks; explicitly authorize streamlined and
ministerial review in both SOFA areas; and designate the SOFA 2 compatibility
requirements and SOFA design guidelines as applicable to discretionary review only. A
project that does not meet one or more ODS goes to full discretionary ARB review
(Track 1).
Historic Resource Review: Align historic resource review with the citywide Chapter
16.49 process, in place of the SOFA-specific ARB/HRB review of all projects, while
keeping SOFA-specific protections. Fold SOFA 2’s separate Historic Resource List into
the citywide Historic Resources Inventory and remove the Potential History Resources
List. Keep SOFA 2’s stronger historic demolition permit and procedures.
Regulatory Vehicle for SOFA ODS: Create a new standalone Title 18 chapter for
SOFA referencing PAMC Chapter 18.24/citywide standards by incorporation for topics
already covered and providing SOFA-specific standards for the remainder, as well as
clarification on review procedures. SOFA plan documents receive a cross-reference note
to the new chapter for streamlined/ministerial projects.
Objective Design Standards: SOFA guidelines that can be made measurable will be
drafted as objective standards. Guidelines will be retained for Track 1 discretionary ARB
review, with applicability language confirming they do not apply to ministerial projects.
Development Standards: Development standards will be brought into the new SOFA
Title 18 chapter, along with the design standards. Any subjective language will be
removed or made objective.
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 36
Outdated Content: The project team will compile a list of outdated and superseded
provisions, and recommends a backstop clause in the new chapter (or a short note
appended to each plan) providing that State law prevails where it conflicts with SOFA
provisions.
Item 3
Attachment A - South of
Forest Area (SOFA)
Coordinated Area Plans -
Recommended Approach
Options for Objective
Design Standards
Packet Pg. 37
Item 3
Attachment B - SOFA I & II
Map
Packet Pg. 38