Exhibit_C_-_375_Hamilton_Ave_EIR_Addendum.pdf

Hamilton Avenue Parking Garage

EIR Addendum Checklist

State Clearinghouse No. 2017052040

Prepared by

May 28, 2026

PAGE WAS LEFT BLANK INTENTIONALLY

Environmental Checklist for Sections 15162- 15164 Findings (For projects with a previously approved EIR or Negative Declaration)

Hamilton Avenue Parking Garage Project Update

The California Environmental Quality Act (CEQA) Guidelines Sections 15162 through 15164 set forth the criteria for determining the appropriate level of additional environmental documentation, if any, to be completed when there is a previously adopted Negative Declaration (ND), Mitigated

Negative Declaration (MND), or a previously certified Environmental Impact Report (EIR) covering the project for which a subsequent discretionary action is required. This Environmental

Checklist has been prepared to assist the City in determining whether any additional environmental documentation is needed for the subject discretionary action. This Environmental Checklist is intended to be used to determine the appropriate level of second-tier environmental review, if any, and is not intended to be used for projects not previously analyzed.

1. Background on the Previously Certified EIR:

An EIR for the Palo Alto Parking Garage at 375 Hamilton Avenue (State Clearinghouse

No. 2017052040) was released as a Draft EIR on May 18, 2018, with a public review period ending on July 2, 2018. The Final EIR, including responses to comments, was finalized on

August 10, 2018. The City Council certified the Final EIR and adopted the associated

Mitigation Monitoring and Reporting Program on February 11, 2019. The certified EIR determined that, with the implementation of mitigation measures, all potentially significant impacts of the project would be reduced to less than significant levels. No impacts were found to be significant and unavoidable; therefore, a Statement of Overriding

Considerations was not required.

Impacts found to be less than significant or reduced to less than significant with mitigation measures included Aesthetics (including light and glare), Agriculture and Forestry

Resources, Air Quality (construction, operational, and plan consistency), Biological

Resources, Cultural and Tribal Resources, Energy, Geology and Soils, Greenhouse Gas

Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Noise, Public Services, Transportation and Circulation, and Utilities and

Service Systems.

A Notice of Determination (NOD) was filed with the Santa Clara County Clerk following certification of the EIR on February 13, 2019.

2. Lead Agency Name and Address:

City of Palo Alto

250 Hamilton Avenue

Palo Alto, California 94301

Holly Boyd, Assistant Director of Public Works

Phone (650) 329-2612

E-mail: holly.boyd@paloalto.gov

3. Summary of the Project Evaluated in the Previously Adopted EIR:

At the time the 2018 EIR was certified, the project consisted of a parking garage with five above-ground parking levels and one basement parking level, with parking provided on the roof level. The structure reached a height of 49 feet-10 inches to the top of the rail of the fifth deck and 63 feet at the top of the elevator. The parking garage replaced the existing

City-owned surface parking facility on the western corner of Hamilton Avenue and

Waverley Street. The garage footprint covered 23,490 square feet, with approximately

114,048 square feet of above-grade floor area. The Previously Approved Project provided a total of 325 parking stalls, including approximately eight Americans with Disabilities Act

(ADA) accessible stalls and 82 stalls designated for electric vehicles (with 17 equipped with charging stations), as well as nine stalls designated specifically for the retail area use.

An approximately 585-square-foot bicycle parking area with approximately 50 bicycle parking stalls and space for bicycle trailers and child carriers were located near the entrance along Hamilton Avenue. The project also included an approximately 2,000-square-foot single or dual-tenant commercial retail space fronting Waverley Street. The parking structure was designed to accommodate future photovoltaic panels mounted above the uppermost parking deck. The top level of the photovoltaic structure, approximately 56 feet above grade, was below the top of the elevator. The parking structure included a 3-foot setback along Hamilton Avenue, and a trash enclosure with an area for trash and recycling from adjacent properties on Waverley Street (Lots 84 and 85) and for the retail area.

4. Does the project for which a subsequent discretionary action is now proposed differ in any way from the previously approved project?

YES ☒ NO ☐

The overall purpose, location, and general scale of the project remain consistent with the

Previously Approved Project; however, the project currently being evaluated includes design refinements that differ slightly from the Previously Approved Project. Key changes include the removal of the ground-floor retail space and the basement-level parking garage, addition of a sixth above-ground level, inclusion of a publicly accessible plaza, and a reduction in total parking from 325 to 266 stalls. The environmental analysis in this

Addendum evaluates whether these changes would result in new significant impacts or a substantial increase in the severity of the previously identified impacts.

mailto:holly.boyd@paloalto.gov

SUBJECT AREAS DETERMINED TO HAVE NEW SIGNIFICANT

ENVIRONMENTAL EFFECTS OR SUBSTANTIALLY MORE SEVERE

SIGNIFICANT ENVIRONMENTAL EFFECTS COMPARED TO THOSE

IDENTIFIED IN THE PREVIOUS ND OR EIR

The subject areas checked below were determined to be new significant environmental effects or to be previously identified effects that have a substantial increase in severity either due to a change in project, change in circumstances or new information of substantial importance, as indicated by the checklist and discussion on the following pages.

☒None

☐Aesthetics ☐Agriculture Resources ☐Air Quality

☐Biological Resources ☐Cultural Resources ☐Energy

☐Geology/Soils ☐Greenhouse Gas Emissions ☐Hazards and Haz Materials

☐Hydrology/Water Quality ☐Land Use/Planning ☐Mineral Resources

☐Noise ☐Population/Housing ☐Public Services

☐Recreation ☐Transportation ☐Tribal Cultural Resources

☐Utilities/Service Systems ☐Wildfire ☐Mandatory Findings of

Significance

Determination:

On the basis of this analysis, the Planning and Development Services Department has determined that:

☒ No substantial changes are proposed in the project and there are no substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous EIR or ND due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Also, there is no

"new information of substantial importance" as that term is used in CEQA Guidelines Section

15162(a)(3). Therefore, the previously adopted ND or previously certified EIR is adequate upon completion of an ADDENDUM.

☐ No substantial changes are proposed in the project and there are no substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous EIR or ND due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Also, there is no

"new information of substantial importance" as that term is used in CEQA Guidelines Section

15162(a)(3). Therefore, because the project is a residential project in conformance with, and pursuant to, a Specific Plan with a EIR completed after January 1, 1980, the project is exempt pursuant to CEQA Guidelines Section 15182.

☐ Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous ND due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or there is "new information of substantial importance," as that term is used in CEQA Guidelines Section 15162(a)(3).

However, all new significant environmental effects or a substantial increase in severity of previously identified significant effects are clearly avoidable through the incorporation of mitigation measures agreed to by the project applicant. Therefore, a SUBSEQUENT ND is required.

☐ Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous ND or EIR due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or there is "new information of substantial importance," as that term is used in CEQA Guidelines Section

15162(a)(3). Therefore, a SUBSEQUENT or SUPPLEMENTAL EIR is required.

Signature Date

Printed Name Title

1. Introduction CEQA Guidelines Sections 15162 through 15164 set forth the criteria for determining the appropriate additional environmental documentation, if any, to be completed when there is a previously certified Environmental Impact Report (EIR) or adopted Negative Declaration for a project.

CEQA Guidelines Section 15162(a) and 15163 state that when an EIR has been certified or a

Negative Declaration adopted for a project, no Subsequent or Supplemental EIR or Subsequent

Negative Declaration shall be prepared unless the lead agency determines, based on substantial evidence in light of the whole record, that one or more of the following conditions exist:

1. Substantial changes are proposed in the project which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

2. Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

3. New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the Negative Declaration was adopted, shows any of the following:

a. The project will have one or more significant effects not discussed in the previous

EIR or Negative Declaration; or

b. Significant effects previously examined will be substantially more severe than shown in the previously adopted Negative Declaration or previously certified EIR;

or

c. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents declined to adopt the mitigation measure or alternative; or

d. Mitigation measures or alternatives which are considerably different from those analyzed in the previous Negative Declaration or EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

CEQA Guidelines Section 15164(a) further provides that an Addendum to a previously certified

EIR may be prepared if minor changes or additions are necessary but none of the conditions described in Section 15162 calling for a Subsequent or Supplemental EIR have occurred.

If the factors listed in CEQA Guidelines Sections 15162, 15163, or 15164 have not occurred or are not met, no changes to the previously certified EIR or previously adopted ND are necessary.

The Addendum is only required to analyze those environmental topics addressed in the original certified EIR. This precedent has been set in two appellate court decisions upholding the preparation of an Addendum for a previously certified EIR Concerned Dublin Citizens V. City of

Dublin, 214 Cal.App.4th 1301 (2013) and Citizens for Responsible Equitable Environmental

Development V. City of San Diego, 196 Cal.App.4th 515 (2011). In both cases the lead agency prepared an Addendum to a previously certified EIR. These appellate court decisions indicate that the issues discussed in an Addendum may be limited to those addressed in the original EIR. They also indicate that “changed circumstances” means physical changes, not legal changes. Based on the analysis in this Addendum, none of the conditions described in CEQA Guidelines Sections

15162 or 15163 have occurred, and no new significant environmental effects or substantially more severe impacts would result from the revised design. Therefore, an Addendum to the previously certified EIR is the appropriate level of environmental documentation.

1.1. Background of the Previously Approved EIR

1.1.1. Final 2018 EIR

The City of Palo Alto prepared and certified the Parking Structure at 375 Hamilton Avenue Final

EIR (State Clearinghouse #2017052040) on February 11, 2019. The Final EIR analyzed four scenarios (scenarios 1, 2, 3, and 4) and their environmental impacts. The City also prepared and adopted a Mitigation, Monitoring and Reporting Program (MMRP) and certified it on February

11, 2019, as well as certifying a Council Resolution (No. 9818) on February 11, 2019.

1.1.2. City of Palo Alto 2030 Comprehensive Plan

The project would be located entirely in the City of Palo Alto. The 2030 Comprehensive Plan is the fundamental document that governs land use development. It includes goals and policies relating to economic vitality, land use, growth management, transportation, parks, open space, conservation, safety, noise, public facilities, and utilities. The project would be required to abide by all applicable goals and policies in the 2030 Comprehensive Plan. The 2030 Comprehensive

Plan land use designation for the site is Regional/Community Commercial (CC), which is intended for “districts that have a wider variety of goods and services than the neighborhood shopping areas.

They rely on larger trade areas and include such uses as department stores, bookstores, furniture stores, toy stores, apparel shops, restaurants, theaters and non-retail services such as offices and banks. Examples include Stanford Shopping Center, Town and Country Village and University

Avenue/Downtown. Non-residential floor area ratios (FARs) range from 0.35 to 2.0. Consistent with the Comprehensive Plan’s encouragement of housing near transit centers, higher density multi-family housing may be allowed in specific locations. The proposed project would provide parking to support the University Avenue/Downtown shopping area. In addition, the project includes a future housing component that could add affordable residential units on an underutilized site, consistent with 2030 Comprehensive Plan policies L-1.3 and L-1.4 and the City’s adopted

Housing Element.

1.1.3. CEQA Guidelines Update

Since the time the 2018 EIR was certified, the CEQA Guidelines have been updated by the State of California; the revised Guidelines are in effect as of December 2018. Therefore, this Addendum is based on the 2025 Appendix G checklist questions in the updated CEQA Guidelines. The current

CEQA Guidelines Appendix G checklist questions provide the basis for this analysis.

2. Project Description As noted earlier, the 2018 Final EIR (2018 EIR) evaluated four (4) design scenarios. The design currently being evaluated (revised design) is most similar to design scenario number 3. However, the revised design is not the same; therefore, the following text describes the design currently being evaluated in this Addendum (revised design).

The revised design is a six-story public parking garage consisting of six above-ground parking levels. The uppermost level would provide parking spaces on the roof. The structure would reach a height of 59’-11” to the top of the rail of the sixth deck and to a height of 72’-6” feet at the top of the elevator. The public parking garage footprint would cover 19,015 square feet, with a total building area of 117,168 square feet.

The garage would provide 266 parking stalls, including ten Americans with Disabilities Act

(ADA) accessible spaces (three of which would be designated for electric vehicles).

Approximately 100 stalls are planned to be designated for electric vehicle use with 42 initially equipped with charging stations. In total, 38 percent of the parking spaces would be designed to allow the future installation of charging stations, per the City of Palo Alto Green Building Code1.

Initially, 15 percent, or approximately 42 stalls, of the parking spaces would be equipped with a charging station. A 368-square-foot bicycle parking area located near the structure entrance along

Hamilton Avenue would provide approximately 42 bicycle parking spaces.

The revised design would also include a publicly accessible plaza adjacent to the garage, sized at approximately 4,048 square feet, replacing the previously approved/proposed retail component.

The garage structure would be designed to accommodate the installation of photovoltaic panels and their associated structure above the garage’s uppermost deck. The top level of the photovoltaic framework, at 68’0” feet above grade, would be below the top of the elevator, at 72’6” feet above grade.

The garage structure would be designed with a 2-foot setback from the property line along

Hamilton Avenue (to the face of structure). Sidewalk improvements would be provided along both street frontages. Along Hamilton Avenue, the sidewalk would be 12 feet from the property line

(14 feet total). Along Waverley Street, the sidewalk/bulb-out would be approximately 17 feet 9 inches, tapering to approximately 11 feet 9 inches to match with the existing sidewalk to the north.

Table 1 below presents a summary of the project.

1 City of Palo Alto, Ordinance No. 5263, Amendment to the California Green Building Standards Code, August 4, 2014, https://www.cityofpaloalto.org/civicax/filebank/documents/43818, accessed on November 6, 2017.

https://www.cityofpaloalto.org/civicax/filebank/documents/43818

Table 1: Project Summary

Use/Characteristics Amount/Description Project

Parking 266 stalls 95,962 sf

Circulation Elevator lobbies, ramp, stairs 18,996 sf

Utilities Electrical, Mechanical and

Trash Rooms

1,648 sf

Storage 194 sf

Bike Parking 42 spaces 368 sf

Total Area 117,168 sf

Note: sf = square feet

Source: Watry Design, May 2026

Figure 1 shows the overall site plan. Figure 2 through Figure show the floor plans for each level of the project, illustrating parking layouts, pedestrian and bicycle circulation, and the publicly accessible plaza. Figure through Figure show the structure elevations and sections of the revised design highlighting the structure height, setbacks, and façade design.

Figure 1: Site Plan

Figure 2: Parking Structure Ground Level

Figure 3: Level 02 and 03 Floor Plan

Figure 4: Level 04 and 05 Floor Plan

Figure 5: Level 6 and PV Plan

Figure 6: Elevations of Proposed Parking Structure from Hamilton Avenue

Figure 7: Elevations of Parking Structure from Waverley Street

Figure 8: Sections of Revised Design

2.1. Structure Design

The proposed structure would extend 5 feet into the required 7 foot special setback along Hamilton

Avenue (providing a 2-foot setback from the property line) and along Waverley Street edge, as well as the interior side lot line shared with the adjacent AT&T building. At the property line shared with the southeastern side of Lot 85 (or 558-560 Waverley Street), the edge of the garage would be set back 10 feet from the property line, allowing openings for natural ventilation into the parking garage, as well as light to reach the existing windows of the property at 558-560 Waverley

Street. This necessary setback would also create an opportunity for a pedestrian walkway, which would be ADA-accessible, leading to the secondary stairway. At the property line shared with Lot

84 and the southwestern side of Lot 85, the garage would be set back 16 feet to maintain access for utilities, service, and a secondary means of egress for the existing buildings fronting Waverley

Street. Vehicle access in this alley would be restricted to those needed for servicing the adjacent properties. Additionally, the alley would be enhanced with architectural paving, new plantings, benches, and lighting so that it can be a usable space. The project would also include a publicly accessible plaza at the west corner of Hamilton Avenue and Waverley Street, which would provide outdoor gathering space and enhance pedestrian activity. Sidewalks along Hamilton Avenue and

Waverley Street would be replaced and widened. Along Hamilton Avenue, the sidewalk would be

12 feet from the property line (14 feet total). Along Waverley Street, the sidewalk/bulb-out would be approximately 17 feet 9 inches, tapering to approximately 11 feet 9 inches to conform with the existing sidewalk to the north.

The project’s façade design is intended to be compatible with the surrounding architectural context, and to reflect the character of Palo Alto’s Downtown. Potential locations for the integration of public art have also been identified, including the perforated metal panels above the corner stairs and the vehicle entry.

The primary construction material would be concrete, including columns, slabs and walls. Along street frontages, architecturally treated concrete columns and shear walls in a neutral, natural color palette would complement surrounding development. Pedestrian-oriented screening would be provided at the ground floor through decorative metal elements integrated into building openings and stair features, drawing inspiration from metal detailing found in nearby Spanish Revival-style buildings. A perforated metal screen would wrap the primary corner stairs, creating a lantern-like architectural feature that serves as a visual landmark and wayfinding element and would incorporate a public art component. Upper-story facades would include vertical metal elements between columns to define the building mass while accommodating garage ventilation. The overall material palette and architectural detailing would be consistent with applicable provisions in the city’s Historic Preservation Ordinance (Municipal Code Chapter 16.49) for the area.

Figure shows the proposed architectural character and massing of the parking structure.

Figure 9: Rendering for Proposed Parking Structure (View from corner of Hamilton Avenue and Waverley Street)

2.1.1. Access Points

The project can be accessed by vehicles via an entrance and exit on Hamilton Avenue. Lane 21 would continue to be one-way circulation, with the entrance on Waverley Street and the exit on

Bryant Street. A pedestrian pathway through the structure leads from the bike parking entry near

Waverley Street to Lane 21 near the CVS. City Council has not yet decided whether the facility would be a paid parking lot and thus, there is space reserved to accommodate the provisional gates at the entrance and exit. Gates and access points are shown on the ground floor plan (Figure 1).

2.1.2. Utilities

Construction of the revised design would require the relocation of the existing fiber optic and high voltage electric lines. Existing electrical and fiber utilities under the site would be redirected prior to construction to allow utilities crossing the site to be abandoned. Based on current design understanding, new transformers would be located above ground along Lane 21, which would avoid the need for below-ground transformer vaults or other subsurface utility vaults. A connection may also be provided from a pad location along Lane 21 to a stub-up nearer the plaza to allow for future residential service.

2.1.3. Transportation

Pedestrian safety improvements at the intersection of Waverley Street and Hamilton Avenue would be included as part of the project. Improvements within the project would include modifications to existing sidewalk and curb ramp features (e.g., pedestrian curb ramps/curb returns) in the public right-of-way at the Waverley Street and Hamilton Avenue intersection to improve accessibility and pedestrian circulation.

2.1.4. Landscaping

The proposed parking structure landscaping is designed to enhance the downtown Palo Alto pedestrian environment and to encourage social interaction through an inviting streetscape. The project landscaping would also encourage social interaction by creating a unique and convenient pedestrian paseo between the existing surrounding buildings and the proposed structure.

The project proposes construction of a parking garage and new surrounding hardscape. Six (6) trees are proposed for removal, of which all are City-protected trees under the City of Palo Alto’s

Tree Technical Manual, including a Coast Live Oak (Quercus agrifolia) (additional trees became protected during a pause in the project). Tree removals and protection status are documented in the Arborist Report and tree removal plan. Tree removals and protection status are documented in the Arborist Report and tree removal plan in the Arborist plan set. The Arborist’s report indicates that previous, imprecise pruning of the Coast Live Oak has resulted in the poor condition of the tree and a potential for breakage, removal and replacement would occur in accordance with City requirements.

New pavement is proposed within the TPZ of one City-protected street tree and one non-protected private tree. Another protected street tree would be preserved but is located outside the area of development. Existing street trees along Waverley Street would remain. No canopy pruning is anticipated.

All tree removals associated with the project would require replacement. The replacement standards outlined in the City of Palo Alto Tree Technical Manual (as described in the 2018 EIR) would be utilized to achieve no net loss of canopy per Policy 1.G of the Urban Forest Master

Plan[2]. Site preparation and soil volume requirements would apply so that newly planted trees have the potential to mature to desired size and thrive.

The corner of the parking structure would feature a mini park featuring decorative pavers, which are also used in the pedestrian access alleyways, a concrete plaza, plantings and linear concrete benches. In the pedestrian walkway, decorative pervious pavement, generous benches, landscaped storm water treatment planters, and pedestrian-scaled lighting would be used to invite pedestrian use. Storm water planters along the walkway would be raised to capture and cleanse storm water directed from the parking structure deck. These planters would feature a combination of low-growing, knee-high foliage and flowering plants that provide year-round interest and function.

Columnar gingko trees, similar to the surrounding street trees, would be introduced where width allows to further enhance the pedestrian environment and create a pleasant atmosphere for what is intended to become a well-used passageway.

The streetscape walkways would be widened to provide more room for circulation around the public plaza on Waverley Street and to allow room for enjoying the built-in benches and landscaped raised planters on Hamilton Avenue. New street trees proposed along Hamilton

Avenue would be placed in larger four-foot by seven-foot tree wells with a suspended pavement system to help ensure healthy growth. The new trees (Ginkgos) would reflect the existing species of the preserved street trees on Waverley Street. Three native Oak trees would be added on

Hamilton Avenue to compensate for the removal of the one protected oak tree.

2.1.5. Foundation and Excavation

The revised design would not include a basement level. Standard foundation work for the above-grade structure would be required. A site survey determined that the site elevation ranges between

49 and 51 feet below sea level. No below grade geotechnical ground improvement or piling is expected. No major soil fill is anticipated. Any minor, localized fill would be limited to areas associated with the Level 1 ramp/slab-on-grade configuration and would not constitute substantial grading or import of fill.

2.1.6. Construction

Construction of the parking structure is expected to last 18 months and would be separated in the following phases:

• Utility relocations are expected to last three to four months and would be coordinated with the City of Palo Alto Utilities (CPAU) for electric and wastewater, AT&T for data, and others to be determined further in the design.

• Demolition and excavation of the site is anticipated to last approximately two to four months and would occur simultaneously with the utility relocations.

• Construction of the structure is expected to last eight months.

Construction days and hours will be in accordance with the City of Palo Alto’s Noise Ordinance, as follows:

• Monday through Friday: 8:00 A.M. to 6:00 P.M.

• Saturday: 9:00 A.M. to 6:00 P.M.

• Sundays and Holidays: Construction prohibited.

2.1.7. Staging and Storage Area

There is limited space for staging and storage on the project site. To maintain sidewalk access for pedestrians, staging and storage would be kept on the parcel and rotated as construction progresses.

The project construction would result in sidewalk closures during some stages of construction to facilitate the sidewalk improvements and bulb outs. Pedestrians would be diverted across the street during sidewalk improvement work. Road narrowing and possible temporary road restrictions may be required. The existing bus stop shown on the plans may be temporarily relocated during construction, as needed, to maintain transit service and safe pedestrian access. The temporary relocation and any associated signage or stop amenities would be coordinated with the Valley

Transportation Authority (VTA). Upon completion of construction, the bus stop would be restored to its planned location, consistent with transit operations.

2.2. Project Changes from Previously Approved Project

The project has been refined from the version analyzed in the certified EIR. The following summarizes the primary changes in design, features, and site use:

• Basement Level: The Previously Approved Project included a basement level. The revised design does not include a basement.

• Retail Component: The Previously Approved Project included retail space along

Waverley Street. The revised design replaces the retail space with a publicly accessible plaza.

• Parking Capacity and Layout: The Previously Approved Project included 325 parking stalls, eight ADA accessible stalls, and 82 EV designated stalls. The revised design provides 266 parking stalls, including approximately 100 electric vehicle spaces, 42 of which would initially be equipped with charging stations, and ten ADA accessible stalls.

The revised design also includes 42 bicycle parking spaces with additional space for child carriers, slightly less than the 50 bicycle parking spaces included in the Previously

Approved Project.

• Structure Height and Massing: The Previously Approved Project proposed a structure height of 49’-10” to the top of the fifth-deck rail and 63 feet to the top of the elevator. The revised design reaches a height of 59’-11” to the top of the sixth-deck rail and 72’-6” to the top of the elevator.

• Setbacks and Sidewalks: The Previously Approved Project proposed the following setbacks and sidewalks widths respectively, 3-foot setback along Hamilton to the face of the structure, a 10’-0” setback along the southeastern side shared with Lot 85, and a 16’ setback along the southwestern side shared with Lots 84 and 85, a sidewalk width of 12’ along Hamilton Avenue, and a 17’-9” sidewalk/bulb/out along Waverley Street. The revised design extends 5 feet into the required 7 foot special setback along Hamilton

Avenue, leaving a 2-foot setback from the property line to the face of structure, a 10’ setback along the southeastern side shared with Lot 85, and a 16-foot setback along the southwestern side shared with Lots 84 and 85. Along Hamilton Avenue, the sidewalk would extend 12 feet from the property line (14 feet total) and along Waverley Street the sidewalk/bulb-out would be approximately 17 feet 9 inches, tapering to approximately 11 feet 9 inches to conform with existing sidewalk to the north.

• Sustainability Features: The project structure is still designed to accommodate future photovoltaic panels but now the revised design incorporates infrastructure for future EV charging at 38 percent of parking stalls. These higher percentages reflect an increase in sustainable building measures relative to the Previously Approved Project.

• Landscaping and Streetscape: The Previously Approved Project included street trees and basic streetscape improvements along Hamilton Avenue and Waverley Street. The revised design retains and enhances these elements, while also introducing a new publicly accessible plaza, landscaped pedestrian alleyways, stormwater planters, and improved benches and pedestrian pathways. The project proposes removal of six (6) trees, of which all are City-protected trees.

• Access and Utilities: Vehicular access to the revised design would be provided via a single entry/exit driveway on Hamilton Avenue, rather than the multiple access points included in the Previously Approved Project. Pedestrian connectivity to Lane 21 would be maintained through the proposed pedestrian pathway. Utility work would include relocation of existing fiber optic and high voltage electric lines; existing electrical and fiber utilities crossing the site would be redirected prior to construction to allow those facilities to be abandoned. Transformers would be located above ground along Lane 21, avoiding the need for below-ground transformer vaults or other subsurface utility vaults. A connection may also be provided from a pad location along Lane 21 to a stub-up nearer the plaza to allow for future residential service. The revised design would not include a public restroom.

These changes reflect the City’s refinement of the design to respond to site conditions, community input, and contemporary sustainability standards. Potential environmental impacts associated with these changes are addressed in the analysis presented in this Addendum.

2.3. Location of Project

The project is in the City of Palo Alto, California, as shown in Figure . The site is in the University

Avenue area, also known as the Downtown area (per the City of Palo Alto Comprehensive Plan).

The project site is located north of State Route 82 (El Camino Real) and south of U.S. Highway

101. The Palo Alto Caltrain Station is located approximately 2,000 feet southwest of the project site and Stanford University is approximately 0.5 miles southwest of the project site. The project vicinity is shown in Figure 11.

Lot D, currently occupied by a surface parking lot, is located on the western corner of Hamilton

Avenue and Waverley Street, one block east of University Avenue.

Figure 12 provides a view of the Downtown Palo Alto area in relation to the project site.

Figure 10: Regional Map

Figure 11: Project Vicinity Map

Figure 12: Project Location

2.4. Project Setting

2.4.1. Project Site

The project site is located on the western corner of Hamilton Avenue and Waverley Street. The project would be located on a parcel with Assessor Parcel Number 120-15-086. The lot is situated on a generally flat area and has an “L”-shaped configuration with 205 feet of frontage to the south on Hamilton Avenue, 100 feet of frontage to the east on Waverley Street and 62 feet of frontage to the north on Lane 21. The total area of the project site is 29,164 square feet (0.67 acres).

The site is occupied by a surface parking lot that contains 86 existing parking spaces. The layout of the lot includes angled parking stalls with a one‐way drive aisle for circulation. The surface parking is currently limited to hourly parking, with no permit parking provided. Figure 13, shows the actual configuration of the lot.

The project site is located within the PF zoning district according to the City of Palo Alto Zoning

Map and has a Comprehensive Plan Land Use Designation of Community Commercial (CC).

2.4.2. Access Points

There are six existing vehicular access points to the site: three ingress/three egress driveways along

Hamilton Avenue, Waverley Street and Lane 21, respectively.

2.4.3. Adjacent Land Uses

The project site is abutted by four developed sites. These include:

• Lot 102 (or 345 Hamilton Avenue), a building constructed in 1958 and occupied by AT&T and Excel Aviation at time of EIR publication;

• Lot 83 (or 526 Waverley Street), a building constructed in 1928, and Category 2 historic resource; up For Lease as of December 2025;

• Lot 84 (or 550‐552 Waverley Street), a building occupied by the Ethel’s Fancy (550) and

For Lease (552) as of August 2025, and

• Lot 85 (or 558‐560 Waverley Street), a two-story building constructed in 1938, housing the Tai Pan Restaurant on the ground floor and office space on the second floor.

The existing parking lot serves adjacent restaurant and retail uses along Waverley Street and provides pedestrian rear-entry access to the CVS Pharmacy to the west (352-364 University

Avenue) via Lane 21.

2.4.4. Existing Utilities

The project site contains four streetlight poles and active high voltage electric, streetlight, and fiber optic lines running north‐south through the site. Utilities along the site boundaries include electric, water, gas, and sewer to the south, and water, gas, sewer, and storm drain to the east.

Figure 13: 375 Hamilton Avenue

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3. Environmental Review Update Checklist After certification of an EIR, CEQA requires consideration of whether there are changes in the project, changes in circumstances under which it is undertaken, or “new information of substantial importance” that would result in new or more severe impacts. The following analysis and responses to the CEQA checklist questions describe project changes, evaluate whether those changes result in new information or substantial changes in the previously evaluated impacts, and make a significance determination regarding those changes. The CEQA checklist responses support the final “Determination,” statement as to the type of environmental documentation required for the project.

3.1. Aesthetics

Except as provided in Public Resources Code

Section 21099, would the project:

Potentially

Significant

Impact

Less Than

Significant With

Mitigation

Incorporated

Less Than

Significant

Impact

No

Impact

a) Have a substantial adverse effect on a scenic vista?

b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?

c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from a publicly accessible vantage point). If the project is in an urbanized area, would the Project conflict with applicable zoning and other regulations governing scenic quality?

d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?

3.1.1. Project Changes Since Previous EIR

The Previously Approved Project included a basement level. The revised design no longer includes a basement level but instead proposes a sixth level increasing the height of the structure from 49’-

10” to 59’-11” to the top of the sixth-deck rail and from 63’ to 72’-6” to the top of the elevator.

The revised design replaces the retail space along Waverley Street with a publicly accessible plaza.

The Previously Approved Project included street trees and basic streetscape improvements along

Hamilton Avenue and Waverley Street. The revised design retains and enhances these elements, while also introducing landscaped pedestrian alleyways, stormwater planters, and improved benches and pedestrian pathways. Six (6) trees are proposed for removal, all of which are City-protected trees. Removed trees would be replaced consistent with the City’s Tree Technical

Manual to meet current design standards and achieve no net loss of canopy.

3.1.2. Impact Analysis

a) Would the project have a substantial adverse effect on a scenic vista?

The project site is located in the same downtown area as previously evaluated in the 2018

EIR. The site was not identified in the Comprehensive Plan as containing scenic vistas or major view corridors. The revised design, which includes a sixth level and elevator, would not obstruct or degrade any scenic vistas as none were identified. This is consistent with the previous impact conclusion in the 2018 EIR. There would still be No Impact.

b) Would the project substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?

The project site is not located near a state designated scenic highway. The project would remove six (6) protected trees versus the one that was evaluated in the 2018 EIR. During the pause in the project, additional trees became protected; however, the trees are not state designated scenic resources. Removal of the protected trees would not result in impacts to scenic resources as defined under CEQA. Consistent with the 2018 EIR, there would still be no impact.

c) In non-urbanized areas, would the project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from a publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?

Similar to what was analyzed in the 2018 EIR, the revised design proposes to develop the existing surface parking lot into a multi-story parking structure. Compared to the

Previously Approved Project, the revised design would increase the structure height by approximately 10’-1” to the top of the parking deck rail (from 49’-10” at the fifth-deck rail to 59’-11” at the sixth-deck rail) and by approximately 9’-6” to the top of the elevator (from

63’ to 72’-6”). Despite these increases, the revised design would remain compatible with the surrounding urbanized environment, including nearby multi-story buildings (e.g., AT&T building, Post Office, All Saints Episcopal Church). The revised design is being reviewed by the City of Palo Alto Architectural Review Board (ARB) for consistency with applicable zoning and design standards. The revised design is consistent with the previously evaluated impact in the 2018 EIR. Impacts would remain less than significant.

d) Would the project create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area?

The project would introduce lighting typical of downtown residential uses and parking uses.

The revised design’s lighting strategy has remained consistent with the Previously Approved

Project and would comply with City design standards to minimize spillover and glare.

Building materials are not designed to be highly reflective; exterior materials would be reviewed through the City’s design approval process. No substantial new light or glare impacts would occur. As a result, the project would not create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area. The revised design does not propose substantially more reflective surfaces or additional lighting compared to the Previously Approved Project. Impacts would remain less than significant.

3.1.3. Conclusion

The 2018 EIR analyzed potential aesthetic impacts of the project, including consistency with the

City of Palo Alto 2030 Comprehensive Plan, scenic vistas, scenic resources, visual character, and light and glare. That analysis concluded that the proposed development would be consistent with the urban character of downtown Palo Alto and that temporary construction-related visual impacts would be minimized with implementation of measure MM AES-1, which would require aboveground structures to be designed consistent with local zoning codes and applicable design guidelines to minimize features that contrast with neighboring development and to implement standard Best Management Practices (BMPs), such as good housekeeping (maintaining a clean site) during construction. The 2018 EIR determined visual and aesthetic impacts would be less than significant.

The revised design is within the scope of the 2018 EIR and would not result in new or more severe aesthetic impacts than those previously analyzed. The changes noted between the Previously

Approved Project and the revised design do not represent changes in circumstances, or new information of substantial importance that would result in new or more severe significant aesthetic impacts. Consistent with the 2018 EIR, impacts would remain less than significant.

3.2. Agriculture and Forestry Services

Would the project: Potentially

Significant

Impact

Less Than

Significant With

Mitigation

Incorporated

Less Than

Significant

Impact

No

Impact

a) Convert Prime Farmland, Unique Farmland, or

Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the

Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?

b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?

c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public

Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?

d) Result in the loss of forest land or conversion of forest land to non-forest use?

e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?

3.2.1. Project Changes Since Previous EIR

The Previously Approved Project included street trees and basic streetscape improvements along

Hamilton Avenue and Waverley Street. The revised design retains and enhances these elements, including installation of replacement trees and additional landscaping. However, these changes would not affect agricultural or forestry resources because the project site remains within an urbanized area and on a fully developed property, which does not include Prime Farmland, Unique

Farmland, Farmland of Statewide Importance, Williamson Act lands, or forest land.

3.2.2. Impact Analysis

a) Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide

Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?

The project site is in downtown Palo Alto and is designated as Urban and Built-Up Land on the California Department of Conservation Farmland Mapping and Monitoring Program

(FMMP) maps (DOC 2024a). The project site is in the same developed downtown area previously evaluated in the 2018 EIR, which is not mapped as Prime Farmland, Unique

Farmland, or Farmland of Statewide Importance. Therefore, consistent with the 2018 EIR, the revised design would not convert farmland to non-agricultural use. There would still be no impact.

b) Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract?

The project site is in a fully urbanized downtown area and is not subject to agricultural zoning or a Williamson Act contract; therefore, the revised design would not conflict with agricultural zoning or Williamson Act requirements. This is consistent with the 2018 EIR.

There would still be no impact.

c) Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public

Resources Code section 4526), or timberland zoned Timberland Production (as defined by

Government Code section 51104(g))?

The project site is in a fully urbanized downtown area and is not zoned as forest land, timberland, or Timberland Production Zone; therefore, the revised design would not conflict with forest or timberland zoning. This is consistent with the 2018 EIR. There would still be no impact.

d) Would the project result in the loss of forest land or conversion of forest land to non-forest use?

The site is in a fully urbanized downtown area and does not contain forest land. The revised design would occur on the same developed site analyzed in the 2018 EIR and would not involve removal or conversion of forest land to a non-forest use. This is consistent with the

2018 EIR. There would still be no impact.

e) Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?

The revised design would not involve other changes in the existing environment that could convert Farmland to non-agricultural use or forest land to non-forest use because it would occur entirely within an existing, developed downtown setting. The project site and surrounding area do not contain mapped Prime Farmland, Unique Farmland, Farmland of

Statewide Importance, or forest land, and the revised design does not expand the project footprint into any agricultural or forested areas. This is consistent with the 2018 EIR. There would still be no impact.

3.2.3. Conclusion

The 2018 EIR evaluated agriculture and forestry resources and determined the topic was not applicable because the project site is in a fully urbanized setting with no designated farmland, forest land, or timber resources.