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Title 18 — ZONING

Chapter 18.08 — DESIGNATION AND ESTABLISHMENT OF DISTRICTS

Palo Alto Municipal Code · 2026-09 edition · updated 2026-09-29 · Palo Alto

18.08.010 Designation of General Districts

The several classes of general districts into which the city is divided are designated as follows:

Chapter Map Designation Zoning District Name Number

Chapter

Map Designation Zoning District Name Number

R-E Residential estate district 18.10 R-2 Two-family residence district 18.10 RMD Two unit multiple-family residence district 18.10 R-1 Single-family residence district 18.12 RM-20 Low density multiple-family residence district 18.13 RM-30 Medium density multiple-family residence district 18.13 RM-40 High density multiple-family residence district 18.13 CN Neighborhood commercial district 18.16 CC Community commercial district 18.16 CS Service commercial district 18.16 CD Downtown commercial district 18.18 MOR Medical office and medical research district 18.20 ROLM Research, office and limited manufacturing district 18.20 RP Research park district 18.20 GM General manufacturing district 18.20 PF Public facilities district 18.28 OS Open space district 18.28 AC Agricultural conservation district 18.28 PC Planned community district 18.38 HD Hospital district 18.36

(Ord. 5460 § 15, 2019: Ord. 5123 § 4, 2011: Ord. 4964 § 8 (part), 2007: Ord. 4642 § 34, 2000: Ord. 3890 § 2, 1989: Ord. 3663 § 4, 1986: Ord. 3536 § 42, 1984: Ord. 3519 § 1, 1984: Ord. 3512 § 1, 1984: Ord. 3048 (part), 1978)

18.08.020 Designation of Combining Districts

In addition to the classes of general districts set forth in Section18.08.010, the following combining districts are established and designated:

Map Designation Zoning District Name Chapter Number

Map Designation Zoning District Name Chapter Number

R Retail shopping combining district 18.30(A) P Pedestrian shopping combining district 18.30(B) GF Ground floor combining district 18.30(C) H Hotel combining district 18.30(D) L Landscape combining district 18.30(E) AD Automobile dealership combining district 18.30(F) D Site and design review combining district 18.30(G) D Floodplain district regulations 18.30(H) S Single-story height combining district Section 18.12.100 N Nonconforming use amortization combining district 18.30(I) Pedestrian and transit oriented development PTOD 18.34 combining district

(Ord. 4964 § 8 (part), 2007: Ord. 4869 § 32, 2005: Ord. 4642 §§ 35, 40, 2000: Ord. 4016 § 7, 1991: Ord. 3905 § 5, 1989: Ord. 3890 § 3, 1989: Ord. 3497 § 1, 1983: Ord. 3048 (part), 1978)

18.08.030 References to Districts

Reference within this title to residential districts generally and as a grouping, includes all districts identified in this section. Where references are made to more restrictive or less restrictive residential districts, such references shall apply sequentially between the most restrictive and the least restrictive.

Residential District Restrictive Reference

Residential District Restrictive Reference

RE
R-1 (20,000)
R-1 10,000) Most Restrictive
R-1 (8,000)
R-1 (7,000)
R-1
R-2
RMD
RM-20 Least Restrictive
RM-30
RM-40

(Ord. 5554 § 2, 2022: Ord. 5548 § 2, 2022: Ord. 5460 § 15, 2019: Ord. 4869 § 33, 2005: Ord. 3905 § 6, 1989: Ord. 3890 § 4, 1989: Ord. 3048 (part), 1978)

18.08.040 Zoning Map and District Boundaries

(a) The boundaries of districts established by this title shall be shown upon the zoning map. The zoning map, and all amendments, changes, and extensions thereof, and all legends, symbols, notations, references, and other matters shown thereon, shall be a part of this title.

(b) The zoning map, as currently effective, and a record of all amendments, changes, and extensions thereof, shall be maintained as public record in the office of the building official.

(c) The boundaries of each district as shown upon the zoning map, or amendments thereto, are adopted by the ordinance codified in this title, and the specific regulations established in this title for each general district and combining district, and all other regulations applicable therein as set forth in this title are established and declared to be in effect upon all lands included within the boundaries of each and every district as shown upon the zoning map.

(Ord. 3048 (part), 1978)

18.08.050 Areas Not Shown on Zoning Map

All lands now or hereafter included within the incorporated territory of the city, which lands are not included within a general district shown on the zoning map of the city or are not shown as prezoned to a general district in accord with applicable provisions of this title, shall constitute R-1 single- family residence districts.

(Ord. 3048 (part), 1978)

18.08.060 Use and Interpretation of Zoning Map

The following rules shall apply in the determination of the boundaries of any district shown on the zoning map.

(a) Where boundaries are indicated as approximately following street and alley lines, or other identifiable boundary lines, such lines shall be construed to be the district boundary. Where such boundaries are indicated as within street and alley lines, or within identifiable rights-of-way or creeks, the centerline thereof shall be construed to be the district boundary.

(b) In unsubdivided property, and where a district boundary divides a lot, the location of the district boundary, unless the same is indicated by dimensions, shall be determined by use of the scale appearing on the zoning map.

(c) A symbol, or symbols, indicating the classification of property on the zoning map shall in each instance apply to the whole of the area within the district boundaries.

(d) Where a public street, alley, or right-of-way is officially vacated or abandoned, the regulations applicable to abutting property shall apply equally to each half of such vacated or abandoned street, alley, or right-of-way.

(e) Should any uncertainty remain as to the location or meaning of a boundary or other feature indicated upon the zoning map, said location or meaning shall be determined by the building official.

(Ord. 3048 (part), 1978)

18.08.070 Application of Regulations to Sites Divided by Zone Boundaries

Wherever it is found, pursuant to Section 18.08.060, that a lot or site is divided by the boundary between districts, the provisions of the zoning regulations applicable within each district shall apply to each portion of the site situated in a separate district.

(Ord. 3048 (part), 1978)

18.08.080 Interpretation of Land Use Classifications

The PCE Director shall have the authority to interpret whether a land use is similar to other permitted or conditionally permitted land uses listed in any Zoning District. Such interpretations may be appealed in accordance with Section 18.77.070(f). Staff shall prepare a quarterly information Report to the Council summarizing all final interpretations made under this section.

(Ord. 5373 § 7, 2016)

Chapter 18.09

Accessory Dwelling Units and Junior Accessory Dwelling Units

18.09.010 Purpose.

The intent of this chapter is to provide regulations to accommodate accessory and junior accessory dwelling units (ADU/JADU), in order to provide for variety to the city's housing stock and additional affordable housing opportunities. These units shall be separate, self-contained living units, with separate entrances from the main residence, whether attached or detached. The standards below are provided to minimize the impacts of units on nearby residents and throughout the city, and to assure that the size and location of such dwellings is compatible with the existing or proposed residence(s) on the site and with other structures in the area.

(Ord. 5656 § 2 (part), 2025: Ord. 5574 § 2 (part), 2023: Ord. 5507 § 3 (part), 2020)

18.09.020 Applicable Zoning Districts.

The establishment of an accessory dwelling unit is permitted in zoning districts when single-family or multi-family residential is a permitted land use. The development of a single-family home, ADU, and/or a JADU on a lot that allows for single-family development shall not be considered a multi- family development pursuant to PAMC Section 18.04.030, nor shall they require architectural review pursuant to other sections of Chapter 18.

(Ord. 5656 § 2 (part), 2025: Ord. 5574 § 2 (part), 2023: Ord. 5507 § 3 (part), 2020)

18.09.030 Units Exempt from Generally Applicable Local Regulations.

(a) Government Code section 66323 provides that certain units shall be approved notwithstanding state or local regulations that may otherwise apply. The following types of units shall be governed by the standards in this section. In the event of a conflict between this section and Government Code section 66323, the Government Code shall prevail.

  1. An ADU and JADU within the existing space of a single-family dwelling or an ADU within the existing space of an accessory structure (i.e. conversion without substantial addition).

  2. An ADU and JADU within the proposed space of a single-family dwelling.

  3. A detached, new construction ADU on a lot with a proposed or existing single-family dwelling, provided the ADU does not exceed 800 square feet, four-foot side and rear (i.e. interior) setbacks, or the maximum height described in subparagraph (A), (B), or (C) of paragraph (4) of subdivision (b) of Government Code Section 66321, as applicable.

  4. ADUs created by conversion of portions of existing multi-family dwellings not used as livable space.

  5. Up to eight detached ADUs on a lot with an existing multi-family dwelling, provided that the number of ADUs does not exceed the number of existing units on the lot.

  6. Up to two detached ADUs on a lot with a proposed multi-family dwelling.

(b) The Development Standards for units governed by this section are summarized in Table 1. Regulations set forth in section18.09.040 do not apply to units created under 18.09.030. The minimum and maximum sizes indicated in Table 1 do not prohibit units that are greater than 800 square feet. These sizes simply serve to distinguish when a unit transitions from regulations set forth in Table 1 and section 18.09.030 to regulations set forth in Table 2 and section 18.09.040.

Table 1: Development Standards for Units Described in Government Code Section 66323

Single-Family Multi-Family Conversion of Space Construction of Conversion of Non- Conversion or Conversion or Within the Existing Attached ADU Within Habitable Space Construction of Construction of New Construction of Space of a Single- the Proposed Space Within Existing Multi- Detached(4) ADU on a Detached(4) ADU on a Detached ADU Family Home or of a Single-Family family Dwelling site with Existing Multi- site with Proposed Accessory Structure Home Structure family Structure Multi-family Structure Single-Family Multi-Family Conversion of Space Construction of Conversion of Non- Conversion or Conversion or Within the Existing Attached ADU Within Habitable Space Construction of Construction of New Construction of Space of a Single- the Proposed Space Within Existing Multi- Detached(4) ADU on a Detached(4) ADU on a Detached ADU Family Home or of a Single-Family family Dwelling site with Existing Multi- site with Proposed Accessory Structure Home Structure family Structure Multi-family Structure Up to 8 (not to exceed Number of Units 25% of the existing 1 Attached ADU, 1 Detached ADU, and 1 JADU the number of existing 2 Allowed units (at least one) units on the lot)

Minimum size1 150 sf

Maximum size1 N/A2 800 sf N/A

4 feet from side and N/A, if condition is Underlying zone 4 feet from side and rear lot lines; Setbacks sufficient for fire and N/A standard for Single rear lot lines underlying zoning for safety Family Home front setback

(ADU must be within Daylight Plane N/A N/A
allowable space of
Single-Famil y Home)

Maximum Height3 N/A 165 N/A 165, 6

Parking None

State Law Reference 66323(a)(1) 66323(a)(1) 66323(a)(2) 66323(a)(3) 66323(a)(4)

(1) Lofts where the height from the floor level to the underside of the rafter or finished roof surface is 5' or greater shall count towards the unit's floor area.

(2) The maximum size of a JADU is 500 square feet. See PAMC 18.09.030(h) for additional information.

(3) Units built in a flood zone are not entitled to any height extensions granted to the primary dwelling.

(4) Units must be detached from primary dwellings but may be attached to each other.

(5) A height of 18 feet for a detached ADU on a lot with an existing or proposed single-family or multi-family dwelling unit that is within one-half of one mile walking distance of a major transit stop or a high-quality transit corridor, as those terms are defined in Section 21155 of the Public Resources Code. An additional two feet in height shall be provided to accommodate a roof pitch on an ADU that is aligned with the roof pitch of the primary dwelling unit.

(6) A height of 18 feet for a detached ADU on a lot with an existing or proposed multi-family, multistory dwelling.

(c) Development standards stated elsewhere in this Section or Title 18, including standards related to FAR, lot coverage, and privacy, are not applicable to ADUs or JADUs that qualify for approval under this section. When there is an ADU or JADU attached to an existing or proposed primary dwelling, the shared wall between these units shall contribute to the maximum allowable Floor Area, Lot Coverage, and Maximum House Size of the primary unit. For a single-family home, this measurement shall be taken to the outside stud wall in accordance with Section 18.04.030(a) (65)(D). For a multi-family dwelling, this measurement shall be taken to the outside surface of exterior walls in accordance with Section 18.04.030(a) (65)(B) and (C).

(d) The establishment of accessory dwelling units and junior accessory dwelling units pursuant to this section shall not be conditioned on the correction of non-conforming zoning conditions; provided, however, that nothing in this section shall limit the authority of the Chief Building Official to require correction of building standards relating to health and safety. Upon request of the owner for a delay in enforcement, the Chief Building Official shall delay enforcement of a building standard, subject to compliance with Section 17980.12 of the Health and Safety Code.

(e) The installation of fire sprinklers shall not be required in an accessory dwelling unit if sprinklers are not required for the primary residence. The construction of an accessory dwelling unit shall not trigger a requirement for fire sprinklers to be installed in the existing multifamily dwelling. Nothing in this section shall preclude the Fire Marshal from accepting fire sprinklers as an alternative means of compliance with generally applicable fire protection requirements.

(f) Rental of any unit created pursuant to this section shall be for a term of 30 days or more.

(g) Attached units shall have independent exterior access from a proposed or existing single-family dwelling. Except for JADUs, attached units shall not have an interior access point to the primary dwelling (e.g. hotel door or other similar feature/appurtenance). If a permitted JADU does not include a separate bathroom, the permitted JADU shall include a separate entrance from the main entrance to the structure, with an interior entry to the main living area.

(h) Conversion of an existing accessory structure pursuant to Government Code section 66314(d)(7) may include reconstruction in-place of a non-conforming structure, so long as the renovation or reconstruction does not increase the degree of non-compliance, such as increased height, envelope, or further intrusion into required setbacks. An expansion of not more than 150 square feet beyond the same physical dimensions as the existing accessory structure may be provided to accommodate ingress and egress. Any addition to the existing accessory structure that is not limited to providing for ingress and egress to the unit, and that exceeds the envelope of the existing accessory structure shall be subject to Section 18.09.040.

(i) Street addresses shall be assigned to all units prior to building permit final to assist in emergency response.

(j) The unit shall not be sold separately from the primary residence, except as allowed under Government Code Section 66341.

(k) Replacement parking is not required when an off-street parking space is converted to, or demolished in conjunction with the construction of, an ADU.

(l) JADUs shall comply with the requirements of Section 18.09.050.

(Ord. 5656 § 2 (part), 2025: Ord. 5585 § 2 (part), 2023: Ord. 5574 § 2 (part), 2023: Ord. 5507 § 3 (part), 2020)

18.09.040 Units Subject to Local Standards.

(a) This section shall govern applications for ADUs that do not qualify for approval under Section18.09.030 and for which the city may impose local standards pursuant to Government Code section 66314. Nothing in this section shall be interpreted to prohibit an ADU of up to 800 square feet, at the heights stated in Table 2, with a four foot side and rear setbacks.

(b) The Development Standards for units governed by this section are provided in Table 2. These regulations do not limit the height of existing structures converted into ADUs unless the envelope of the building is proposed to be modified beyond any existing legal, non-conforming condition.

Table 2: All other Units

Attached Detached

Attached Detached

Number of Units Allowed1 1 Minimum size 150 sf

900 sf (1,000 sf for two or more bedrooms); no Maximum size more than 50% of the size of the single-family 900 sf (1,000 sf for two or more bedrooms) home Setbacks 4 feet from side and rear lot lines Daylight Plane Underlying zone standard per footnote (7) N/A Maximum Height3 Res. Estate (RE) 30 feet Open Space (OS) 25 feet All other eligible zones 16 feet(5), (6), (7) Parking None Square Footage Exemption when in Up to 800 sf conjunction with a single family home(4)

(1) An attached and detached ADU may be built in conjunction with a JADU on a lot with an existing or proposed single-family home. One attached or detached ADU may be built in conjunction with an existing or proposed multi-family building.

(2) Lofts where the height from the floor level to the underside of the rafter or finished roof surface is 5' or greater shall count towards the unit's floor area.

(3) Units built in a flood zone are not entitled to any height extensions granted to the primary dwelling.

(4) Lots with both an attached and detached ADU may exempt a maximum combined total of 800 square feet of both the ADUs from FAR, Lot Coverage, and Maximum House Size calculations. Any square footage that exceeds this exemption shall contribute to the FAR, Lot Coverage, and (if attached) Maximum House Size calculations for the subject property. This exemption is not afforded to lots with existing or proposed multifamily dwellings.

(5) A height of 18 feet for a detached ADU on a lot with an existing or proposed single-family or multi-family dwelling unit that is within one-half of one mile walking distance of a major transit stop or a high-quality transit corridor, as those terms are defined in Section 21155 of the Public Resources Code. An additional two feet in height shall be provided to accommodate a roof pitch on an ADU that is aligned with the roof pitch of the primary dwelling unit.

(6) A height of 18 feet for a detached ADU on a lot with an existing or proposed multi-family, multistory dwelling.

(7) A height of 25 feet or the height limitation in the underlying zone district that applies to the primary dwelling, whichever is lower, for an ADU that is attached to a primary dwelling. These ADUs shall not exceed two stories in height.

(c) A single-family or multi-family dwelling shall exist on the lot or shall be constructed on the lot in conjunction with the construction of an ADU.

(d) ADU square footage shall not be included in FAR, lot coverage, and maximum house size calculations for a lot with an existing or proposed single family home, up to the amounts stated in Table 2. ADU square footage in excess of the exemptions provided in Table 2 shall be included in FAR, lot coverage, and maximum house size calculations for the lot.

(e) When there is an ADU attached to an existing or proposed primary dwelling, the shared wall between these units shall contribute to the maximum allowable Floor Area, Lot Coverage, and Maximum House Size of the primary unit. For a single-family home, this measurement shall be taken to the outside stud wall in accordance with Section 18.04.030(a)(65)(D). For a multi-family dwelling, this measurement shall be taken to the outside surface of exterior walls in accordance with Section 18.04.030(a)(65)(B) and (C).

(f) Attached units shall have independent exterior access from a proposed or existing single-family dwelling. Attached units shall not have an interior access point to the primary dwelling (e.g. hotel door or other similar feature/appurtenance).

(g) Reserved.

(h) For properties listed in the California Register of Historical Resources, compliance with the appropriate Secretary of Interior's Standards for the Treatment of Historic Properties shall be required.

(i) Noise-producing equipment such as air conditioners, water heaters, and similar service equipment that exclusively serves an ADU may be located anywhere on the site, provided they maintain the underlying front yard setback requirements of the property and, if the property is a corner lot, a 10-foot street-side setback. All such equipment shall be insulated and housed, except that the Director may permit installation without housing and insulation, provided that a combination of technical noise specifications, location of equipment, and/or other screening or buffering will assure compliance with the city's Noise Ordinance at the nearest property line. All service equipment must meet the city's Noise Ordinance in Chapter 9.10 of the Municipal Code.

(j) Setbacks

  1. Detached units shall maintain a minimum three-foot distance from the primary unit, measured from the exterior walls of structures.

  2. A basement or other subterranean portion that serves an ADU may encroach into a setback required for the primary dwelling provided the

following conditions are met:

(A) Newly constructed basement walls are no closer than four feet to an adjacent interior side or rear property line.

(B) A new lightwell associated with a basement shall not be placed closer than four feet to an adjacent interior property line. When visible

from the right of way, these facilities shall be screened from view with vegetation.

(C) Habitable ADU basements shall contribute toward the unit’s total allowable floor area. Any floor area in excess of the exemptions

provided in this Section shall contribute to the total allowable limits for the site.

  1. Projections, including but not limited to windows, doors, mechanical equipment, venting or exhaust systems, are not permitted to encroach

into the required setbacks, with the exception of a roof eave of up to two feet.

  1. For corner lots developed as a single-family home, when an existing or proposed primary dwelling unit is expanded or constructed

simultaneously with the construction of a new ADU, the homeowner may elect to build all structures to a 10-foot street-side setback and a 16-foot front yard setback, regardless of the presence of a more restrictive special setback, unless a fire or life-safety regulation requires a greater setback. Pursuant to Government Code section 66321(b)(3), a street-side setback may not preclude the development of an 800 square foot unit.

  1. When an existing, legal, nonconforming structure is converted or reconstructed to create an ADU, any portion of the ADU that is in the same

location and falls within the building envelope of the original structure shall not be subject to the development standards stated in this Section. Any portion of the ADU that is in a different location or exceeds the envelope of the original structure shall comply with the development standards stated in this Section.

  1. Notwithstanding the development standards stated in Table 2 and paragraph (5) above, when an existing, legal, non-conforming structure is

converted in place to an ADU, the envelope of the structure may be modified to encroach further into a setback or daylight plane as follows:

(A) The height of the existing structure may be increased by no more than one linear foot in height commensurate to the existing roofline of the structure provided the height of the addition does not exceed 12 feet from grade. The roofline shall not be changed to a style other than what currently exists on the structure.

(B) Each non-conforming wall may be expanded by no more than six inches in thickness based on its existing location and configuration, as

measured to exterior surface of the material, to provide for greater insulation and energy requirements provided that a minimum of one foot is maintained between the addition and an adjacent interior property line. An existing wall of a structure that does not currently have a separation of one foot from a parallel property line shall not be expanded outward.

(C) All other additions not specified here shall follow the standard setbacks for the ADU identified in Table 2.

(k) Design

  1. Except on corner lots, where feasible, the unit shall not have an entranceway facing the same lot line (property line) as the entranceway to

the main dwelling unit unless the entranceway to the accessory unit is located in the rear half of the lot. Exterior staircases to second floor units shall be located toward the interior side or rear yard of the property.

  1. Privacy

(A) Second story doors and decks shall not face a neighboring property line. Second story decks and balconies shall utilize screening barriers

to prevent views towards an adjacent interior property line. These barriers shall be a minimum five-foot, six-inch height, from the floor level of the deck or balcony and shall not include perforations of any kind that would allow visibility between properties.

(B) Windows on a second floor, loft, or equivalent elevated space, excluding those required for egress, shall have a five-foot sill height as

measured from the second-finished floor level, or utilize opaque glazing on the entirety of any window that faces an adjacent interior property line.

(C) Windows on a second finished floor, loft, or equivalent elevated space, shall be offset from neighbor's windows to maximize privacy.

(D) Where feasible, egress windows on the first and second finished floor of an ADU shall not face towards an adjacent interior property line.

If this is not feasible, then these windows shall utilize opaque glazing on the whole window.

(E) If the first finished floor of an ADU is two feet or more above grade, then first floor windows shall include the following:

i. Non-egress, operable windows facing an adjacent interior property line shall have a windowsill(s) that start five feet above the first

finished floor for the unit;

ii. Non-egress, non-operable windows facing an adjacent interior property line shall have the lower half of window(s) (minimum of five feet

above the first finished floor) utilize opaque glazing.

(F) Where feasible, the use of skylights (whether operable or not) shall be used in lieu of operable windows that face adjacent interior

properties.

(G) No exterior lighting shall be mounted above seven feet. All lighting mounted on walls shall be directed downwards and shall not direct

light towards adjacent interior property lines. Any ground lighting shall not direct light upwards to the building or sky.

(l) Parking

  1. Replacement parking is not required when a garage, carport, covered parking structure, or uncovered parking space is converted to, or

demolished in conjunction with the construction of, an ADU.

  1. When parking is provided, the unit shall have street access from a driveway in common with the main residence in order to prevent new curb

cuts, excessive paving, and elimination of street trees, unless separate driveway access will result in fewer environmental impacts such as paving, grading or tree removal.

  1. When a single-family dwelling unit is permitted simultaneously with the construction of new ADUs, the primary unit’s covered parking

requirements identified in Chapter 18.10 and 18.12 do not need to be provided. Two uncovered parking spaces shall be provided in any configuration on the lot including within the front or street-side setback for the property.

4. If covered parking for a unit is provided in any district, the maximum size of the covered parking area for the accessory dwelling unit is 220

square feet. This space shall count towards the total floor area for the site but does not contribute to the maximum size of the unit. Any attached garage shall not have an interior access point to the ADU (e.g. hotel door or other similar feature/appurtenance).

(m) Landscape

  1. For the purposes of this subsection (m), “protected tree” means:

(A) Any locally native tree of the species Acer macrophyllum (Bigleaf Maple), Calocedrus decurrens (California Incense Cedar), Quercus

agrifolia (Coast Live Oak), Quercus douglasii (Blue Oak), Quercus kelloggii (California Black Oak), or Quercus lobata (Valley Oak) which is eleven and one-half inches in diameter (thirty-six inches in circumference) or more when measured four and one-half feet (fifty-four inches) above natural grade.

(B) Any Coast Redwood tree (species Sequoia sempervirens) that is eighteen inches in diameter (fifty-seven inches in circumference) or

more when measured four and one-half feet (fifty-four inches) above natural grade.

(C) Any tree of any species, other than a Coast Redwood Tree, fifteen inches in diameter (forty-seven inches in circumference) or more when measured four and one-half feet (fifty-four inches) above natural grade. A “protected tree” does not include a tree of any species on the Exempt Species List put forth by the Department of Urban Forestry and available on the City’s website.

(D) Any tree designated for protection during review and approval of a current or previously completed development project.

(E) Any tree designated for carbon sequestration and storage and/or environmental mitigation purposes as identified in an agreement

between the property owner and a responsible government agency or recorded as a deed restriction.

(F) Any heritage tree previously designated by the city council.

(G) Any tree previously planted as a replacement mitigation tree.

  1. Except as provided in subsection (3) below, the construction of an ADU shall not impact any protected tree, on the subject property or any

adjacent lot by requiring:

(A) Removal of more than twenty-five percent of the functioning leaf, stem, or root area of a tree in any twenty-four-month period; or

(B) Removal of more than fifteen percent of the functioning root area of any Quercus (oak) species in any thirty-six-month period; or

(C) Trenching, excavating, altering the grade, or paving within the tree protection zone of a tree in a way that foreseeably leads to the death of the tree. For the purposes of this subsection (m), "tree protection zone" means the area defined by a circle with a radius ten times the diameter of the trunk when measured four and one-half feet (fifty-four inches) above natural grade.

3. If an action prohibited by section 18.09.040(m)(2) is necessary to allow the construction of an ADU that meets the minimum standards set

forth in state law, the tree shall be replaced according to the objective requirements identified in the Tree Canopy Replacement Table of the Palo Alto Tree and Landscape Technical Manual.

  1. The construction of an ADU must comply with applicable objective standards and specifications in the Tree and Landscape Technical

Manual for the protection of trees during construction. Compliance with this subsection (4) shall not delay or cause the denial of an ADU or JADU building permit or use permit.

(n) Miscellaneous requirements

  1. Street addresses shall be assigned to all units prior to building permit final to assist in emergency response.

  2. The unit shall not be sold separately from the primary residence except as allowed under Government Code Section 66341.

  3. Rental of any unit created pursuant to this section shall be for a term of 30 days or more.

  4. The installation of fire sprinklers shall not be required in an accessory dwelling unit if sprinklers are not required for the primary residence.

Nothing in this section shall preclude the Fire Marshal from accepting fire sprinklers as an alternative means of compliance with generally applicable fire protection requirements.

(Ord. 5656 § 2 (part), 2025: Ord. 5585 § 2 (part), 2023: Ord. 5574 § 2 (part), 2023: Ord. 5557 § 6, 2022: Ord. 5507 § 3 (part), 2020)

18.09.050 Additional Requirements for JADUs.

(a) A JADU may be created on a lot in a single-family residential zone with an existing or proposed single family residence. A JADU shall be attached to or created within the walls of an existing or proposed primary dwelling, including enclosed uses within the residence, such as an attached garage.

(b) The JADU shall include an efficiency kitchen, requiring the following components: A cooking facility with appliances, and; food preparation counter and storage cabinets that are of reasonable size in relation to the size of the junior accessory dwelling unit.

  1. JADUs may share sanitation facilities (bathrooms, laundry facilities, etc.) with the primary unit. If a permitted JADU does not include a

separate bathroom, the permitted junior accessory dwelling unit shall include a separate entrance from the main entrance to the structure, with an interior entry to the main living area. In this instance, the floor area and lot coverage associated with shared space shall count towards the primary unit’s maximum allowances only. The combined sanitation facilities between the units shall include shower, toilet, and sink fixtures at a minimum and shall conform to the minimum requirements specified in the Building Code.

(c) For the purposes of any fire or life protection ordinance or regulation or for the purposes of providing service for water, sewer, or power, a JADU shall not be considered a separate or new unit.

(d) The owner of a parcel proposed for a JADU shall occupy as a primary residence either the primary dwelling or the JADU. Owner-occupancy is not required if the owner is a governmental agency, land trust, or housing organization.

(e) Prior to the issuance of a building permit for a JADU, the owner shall record a deed restriction in a form approved by the city that includes a prohibition on the sale of the junior accessory dwelling unit separate from the sale of the single-family residence, requires owner-occupancy consistent with subsection (d) above, and restricts the size and attributes of the JADU to those that conform with this section.

(f) JADU incentive. The existing or proposed primary dwelling unit shall be afforded bonus square footage equal to the square footage of a proposed JADU when a JADU is constructed on site, provided the JADU meets the following requirements:

  1. The JADU must conform to the underlying zoning district’s development standards for single family homes.

  2. The maximum number of units on site shall not exceed four (two ADUs, one JADU, and one primary home).

  3. The maximum size of the JADU shall not exceed 500 square feet.

  4. The total maximum bonus/exempt floor area provided for the site under Section18.09.040 and 18.09.050 may not exceed 800 square feet.

  5. The exterior entryway to the JADU shall not face the same direction as the entrance to the primary home.

  6. All egress windows which face an adjacent residential property must utilize opaque glazing on the whole window.

  1. All non-egress windows which face an adjacent residential property must have a windowsill(s) that start five feet above the first finished floor for the unit.

    1. All noise producing equipment associated with the JADU must comply with the noise regulations in PAMC9.10.

(Ord. 5656 § 2 (part), 2025: Ord. 5585 § 2 (part), 2023: Ord. 5574 § 2 (part), 2023: Ord. 5507 § 3 (part), 2020)

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▸Contents — Palo Alto Municipal Code
Palo Alto Municipal Code
  1. Article VIII — A. Board of Education
  2. Title 1 — GENERAL PROVISIONS
  3. Title 2 — ADMINISTRATIVE CODE
  4. Title 4 — BUSINESS LICENSES AND REGULATIONS
  5. Title 5 — HEALTH AND SANITATION
  6. Title 6 — ANIMALS
  7. Title 8 — TREES AND VEGETATION
  8. Title 9 — PUBLIC PEACE, MORALS AND SAFETY
  9. Title 10 — VEHICLES AND TRAFFIC
  10. Title 11 — ENVIRONMENTAL IMPACT PROCEDURE
  11. Title 12 — PUBLIC WORKS AND UTILITIES
  12. Title 13 — IMPROVEMENT PROCEDURE
  13. Title 15 — FIRE PREVENTION
  14. Title 16 — BUILDING REGULATIONS
  15. Title 17 — HAZARDOUS MATERIALS STORAGE
  16. ▸Title 18 — ZONING
    Overview
    1. 18.01 Adoption, Purposes, and Enforcement
    2. 18.04 Definitions
    3. 18.08 Designation and Establishment of Districts
    4. 18.09 Accessory Dwelling Units and Junior Accessory Dwelling U…
    5. 18.10 Low Density Residential (R-E, R-2 and RMD) Districts
    6. 18.13 Multiple Family Residential (RM-20, RM-30 and RM-40) Dis…
    7. 18.14 Housing Incentives
    8. 18.15 Density Bonus
    9. 18.16 Neighborhood, Community, and Service Commercial (CN, CC …
    10. 18.18 Downtown Commercial (CD) District
    11. 18.20 Office, Research and Manufacturing (MOR, ROLM, RP and GM…
    12. 18.24 Contextual Design Criteria and Objective Design Standards
    13. 18.28 Special Purpose Districts
    14. 18.29 North Ventura (NV) District Regulations
    15. 18.30 Combining Districts
    16. 18.31 CEQA Review
    17. 18.34 Pedestrian and Transit Oriented Development (PTOD) Combi…
    18. 18.36 Hospital (HD) District
    19. 18.38 PC Planned Community District Regulations
    20. 18.42 Standards for Special Uses
    21. 18.44 Green Development Regulations
    22. 18.46 Requests for Reasonable Accommodation for Accessibility
    23. 18.52 Parking and Loading Requirements
    24. 18.60 Alternative Development Standards for Stanford Lands
    25. 18.62 Special Regulations for Hazardous Waste Facilities
    26. 18.66 Creation of Easements Through the Execution and Recordat…
    27. 18.70 Nonconforming Uses and Noncomplying Facilities
    28. 18.76 Permits and Approvals
    29. 18.77 Processing of Permits and Approvals
    30. 18.78 Appeals
    31. 18.79 Development Project Preliminary Review Procedures
    32. 18.80 Amendments to Zoning Map and Zoning Regulations
    33. Chapter 18.01 — ADOPTION, PURPOSES, AND ENFORCEMENT
    34. Chapter 18.04 — DEFINITIONS
    35. Chapter 18.08 — DESIGNATION AND ESTABLISHMENT OF DISTRICTS
    36. Chapter 18.10 — LOW-DENSITY RESIDENTIAL (RE, R-2 and RMD) DIST…
    37. Chapter 18.13 — MULTIPLE FAMILY RESIDENTIAL
    38. Chapter 18.14 — HOUSING INCENTIVES
    39. Chapter 18.15 — DENSITY BONUS
    40. Chapter 18.16 — NEIGHBORHOOD, COMMUNITY, AND SERVICE COMMERCIA…
    41. Chapter 18.18 — DOWNTOWN COMMERCIAL (CD) DISTRICT
    42. Chapter 18.20 — OFFICE, RESEARCH, AND MANUFACTURING
    43. Chapter 18.28 — SPECIAL PURPOSE (PF, OS and AC) DISTRICTS
    44. Chapter 18.29 — NORTH VENTURA (NV) DISTRICT REGULATIONS
    45. Chapter 18.30 — COMBINING DISTRICTS
    46. Chapter 18.31 — CEQA REVIEW
    47. Chapter 18.34 — PEDESTRIAN AND TRANSIT ORIENTED DEVELOPMENT (P…
    48. Chapter 18.36 — HOSPITAL (HD) DISTRICT
    49. Chapter 18.38 — PC PLANNED COMMUNITY DISTRICT REGULATIONS
    50. Chapter 18.40 — GENERAL STANDARDS AND EXCEPTIONS
    51. Chapter 18.42 — STANDARDS FOR SPECIAL USES
    52. Chapter 18.44 — GREEN DEVELOPMENT REGULATIONS
    53. Chapter 18.46 — REQUESTS FOR REASONABLE ACCOMMODATION FOR
    54. Chapter 18.52 — PARKING AND LOADING REQUIREMENTS
    55. Chapter 18.54 — PARKING FACILITY DESIGN STANDARDS
    56. Chapter 18.60 — ALTERNATIVE DEVELOPMENT STANDARDS FOR STANFORD
    57. Chapter 18.62 — SPECIAL REGULATIONS FOR HAZARDOUS WASTE FACILI…
    58. Chapter 18.66 — CREATION OF EASEMENTS THROUGH THE EXECUTION AND
    59. Chapter 18.70 — NONCONFORMING USES AND NONCOMPLYING FACILITIES
    60. Chapter 18.76 — PERMITS AND APPROVALS
    61. Chapter 18.77 — PROCESSING OF PERMITS AND APPROVALS
    62. Chapter 18.78 — APPEALS
    63. Chapter 18.79 — DEVELOPMENT PROJECT PRELIMINARY REVIEW PROCEDU…
    64. Chapter 18.80 — AMENDMENTS TO ZONING MAP AND ZONING REGULATIONS
  17. Title 19 — MASTER PLAN
  18. Article 7 — AUTHORITY FOR AND SCOPE OF MASTER OR GENERAL PLANS.
  19. Article 8 — PROCEDURE FOR ADOPTION OF MASTER OR GENERAL PLAN.
  20. Chapter 19.06 — SPECIFIC PLANS
  21. Chapter 19.10 — COORDINATED AREA PLANS
  22. Title 20 — PRECISE PLANS
  23. Title 21 — SUBDIVISIONS AND OTHER DIVISIONS OF LAND
  24. Title 22 — PARKS

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