Local zoning · Palo Alto
Palo Alto — Overlay Districts
Overlay Districts under the Palo Alto local zoning and planning code, with the controlling citations.
Last reviewed: July 2, 2026
Overview
This page explains the overlay and combining districts that modify base zoning in Palo Alto’s municipal zoning code (Title 18). It synthesizes specific Palo Alto overlays and combining districts—what they do, where they apply, and the most decision-relevant numeric standards and procedures—based only on the city ordinance text. For the city’s broader context, see the Palo Alto Zoning overview and the general Palo Alto — zoning & planning overview. § citations below point to the controlling code text; where the ordinance uses site‑specific agreements (Stanford Development Agreement) the code defers to that agreement. See also the city's Development Standards, parking, design review, ADUs, and the state California Building Standards Code for related requirements referenced by the ordinance.
- First mentions of related topics (internal links): Palo Alto Zoning, Palo Alto — zoning & planning overview, Development Standards, parking, Design Review, ADUs, California Building Standards Code.
How this page is grounded
All requirements and procedures below are taken from Title 18 of the Palo Alto Municipal Code (Zoning). Every ordinance citation is given as the controlling section (§ number) and is supported by the retrieved municipal code text. File previews supporting each § are cited inline.
Overlay / Combining Districts — District-by-District
Alternative Standards Overlay Districts (AS1, AS2, AS3) — Chapter 18.60
Purpose: Provide site‑specific, alternative development standards (optional for the affected property owner) to implement the 2005 Stanford Development Agreement; these are applied only to the identified Stanford sites and may replace the underlying zoning when elected by the landowner. See § 18.60.010 – § 18.60.040 for purpose, definitions and applicability.
Where they apply:
- AS1 — El Camino Site / Extended El Camino Site (2450, 2470, 2500 El Camino Real; optional extension including 505 California Ave) § 18.60.050.
- AS2 — Upper California Site (1451, 1501, 1601 California Ave) § 18.60.060.
- AS3 — Mayfield Site (2650, 2700, 2780 El Camino Real) § 18.60.070.
Typical permitted uses:
- AS1: multi‑family residential plus limited commercial (retail/service/eating), child care and live/work lofts; underlying zoning may be displaced if owner elects AS1 § 18.60.050.
- AS2: single‑family, two‑family, and multi‑family residential uses; child care center; BMR provisions per Development Agreement § 18.60.060.
- AS3: public recreation/soccer complex uses with site‑specific modified standards (lighting, fencing) § 18.60.070.
Key dimensional / programmatic standards:
- AS1 and AS2 allow the applicant (Stanford, on those sites) to elect development under the AS standards; if elected the underlying zoning “does not apply” for that site § 18.60.050.A (AS1), § 18.60.060.B (AS2).
- AS2: 20 ft minimum California Avenue frontage setback is specified in the AS2 standards table § 18.60.060.
- AS3: lighting up to 70 ft and ball-control fencing up to 14 ft are explicitly permitted as modified standards § 18.60.070.
- Applicability and elect/ rescind process: Property owner must file notice at time of discretionary review and may rescind its election prior to building permit issuance § 18.60.040.
Practical notes:
- These are site- and owner‑specific overlays tied to the Stanford Development Agreement; they are optional and only identified parcels may use them § 18.60.030.
- For AS1/AS2 some base zoning alternatives are offered as options (e.g., develop under an RM district at applicant’s option)—see § 18.60.050.B and § 18.60.060.B.
Single‑Story Height Combining District (Single‑Story (S) Combining) — § 18.12.100
Purpose: Preserve prevailing single‑story character by limiting structures to single story within mapped combining districts. § 18.12.100 describes applicability, standards and the neighborhood petition process.
- Where it applies: Only when combined with R‑1 or an R‑1 subdistrict (e.g., R‑1(650), R‑1(743)) as shown on the zoning map § 18.12.100(a).
- Permitted uses: Uses remain those of R‑1 (single‑family) but development standards change. § 18.12.100(b).
- Key standards:
- Maximum height 17 ft to roof peak (special flood zones may allow up to 20 ft) § 18.12.100(b)(1).
- Limit of one habitable floor (lofts/mezzanines counted as habitable) § 18.12.100(b)(2).
- Creation/removal process:
- Owner‑initiated application to the Director; creation requires a district map and signatures from 70% of included properties (or 60% where deed restrictions exist) § 18.12.100(c)(2)(B)(C); processed per Chapter § 18.98 (map amendments) § 18.12.100(c)(3).
Pedestrian and Transit Oriented Development (PTOD) Combining District — § 18.34.030 – § 18.34.070
Purpose: Encourage mixed‑use and higher‑intensity housing near transit corridors while managing impacts through specified limits and design/performance standards. § 18.34.040 lists PTOD combining district regulations and development standards tables.
- Where it applies: PTOD boundaries are map‑based (e.g., PTOD — California Avenue, University Avenue placeholders) and properties must be rezoned/combined to PTOD to be subject to the standards § 18.34.060.
- Permitted uses (PTOD — California Avenue example):
- Multiple‑family residential and restricted non‑residential (retail, personal services, limited offices), with certain ground‑floor limitations (see PTOD tables) § 18.34.030 & § 18.34.040.
- Prohibited uses on California Ave PTOD: single‑family/two‑family, heavy manufacturing, and hazardous R&D above exempt quantities § 18.34.030(c).
- Key numeric standards (PTOD — California Ave Table):
- Maximum residential intensity example: 40 DU/AC in the California Avenue PTOD table (see development standards table) § 18.34.040 Table 2.
- Review/rezoning process: Rezoning to PTOD follows Chapter § 18.80 (map amendments) and includes Planning & Transportation Commission and City Council review; upon approval projects go through Architectural Review Board major review § 18.34.060 & § 18.34.040(d).
Hazardous Waste Facility Combining District (HW) — Chapter 18.62
Purpose: Restrict and condition siting of new or expanded hazardous waste facilities; facilities only allowed in a designated Hazardous Waste combining district and must meet county hazardous waste plan siting criteria § 18.62.010.
- Key rules:
- New or expanded hazardous waste facilities prohibited unless located in an HW combining district § 18.62.010(b)–(c).
- Chapter defines facility types, applicable siting criteria, and prohibits residuals repositories § 18.62.020 – § 18.62.060.
Other Combining/Overlay References Found in Title 18
- Retail (R) combining district, Automobile Dealership (AD) combining district, Landscape (L) combining, and others are referenced in chapter use tables and standards (see e.g., CC/CN/CS rules referencing R and AD overlays) § 18.16.060 and Chapters 18.28 / 18.30 references.
Quick Reference Table — Decision‑relevant standards and permitted uses
| Overlay / Combining District | Primary Purpose / Typical Uses | Key numeric or process standards | Code Reference |
|---|---|---|---|
| AS1 (Alternative Standards Overlay 1) | Housing + limited mixed‑use at El Camino Site (Stanford option) | Underlying zoning displaced if AS1 elected; site minimum = El Camino Site; applicant options for base zoning (RM‑40 option) § 18.60.050 | § 18.60.050 |
| AS2 (Alternative Standards Overlay 2) | Housing at Upper California Site; residential uses, childcare | 20 ft California Ave frontage setback; underlying LM zoning displaced if elected § 18.60.060 | § 18.60.060 |
| AS3 (Alternative Standards Overlay 3) | Community soccer fields (Mayfield Site) | Lighting allowed up to 70 ft; fencing up to 14 ft § 18.60.070 | § 18.60.070 |
| Single‑Story (S) Combining | Preserve single‑story neighborhood character (R‑1 only) | Max height 17 ft (20 ft in flood areas), one habitable floor, petition thresholds 70% / 60% § 18.12.100 | § 18.12.100 |
| PTOD — California Avenue | Higher‑intensity transit‑oriented housing + mixed use | Example density 40 DU/AC; mixed‑use ground‑floor rules; rezoning + ARB major review required § 18.34.040 | § 18.34.040 / § 18.34.060 |
| Hazardous Waste (HW) | Control siting of hazardous waste facilities | New/expanded facilities only in HW combining district; siting criteria & prohibitions Chapter 18.62 | § 18.62.010–.060 |
Checklist
An applicant seeking to rely on or establish an overlay/combining district in Palo Alto must (where applicable):
- Confirm the parcel is one of the sites listed for a site‑specific overlay (e.g., El Camino Site, Upper California Site, Mayfield Site) § 18.60.030 . Verify with the jurisdiction.
- For AS1/AS2: at time of discretionary review file the notice electing the AS district and track any rescission deadline (rescission permitted prior to building permit issuance) § 18.60.040 .
- For Single‑Story (S) district creation/removal: prepare district map, owner signature list meeting the 70% (or 60% if deed restrictions) support threshold, and the written statement required by the Director; submit as a zoning map amendment per Chapter 18.98 § 18.12.100(c) .
- For PTOD rezoning: follow Chapter § 18.80 amendments process; plan for Planning & Transportation Commission and City Council rezoning limits and ARB major review after rezoning § 18.34.060 and § 18.34.040(d) .
- For hazardous waste proposals: confirm the site is within a designated HW combining district; otherwise proposals are prohibited § 18.62.010(c) .
- Check related development standards (setbacks, FAR, site coverage) in Development Standards and specific district chapters; consult the city’s parking and Design Review rules early (link to those pages). Verify whether ADUs and other accessory uses are affected by the combining district § 18.09 / cross refs.
Risks & Ambiguities
| Issue | Why it matters | What to verify |
|---|---|---|
| Owner election/rescission rights for AS1/AS2 | Overlay optionality means development approach (and applicable standards) can change based on owner decision and timing § 18.60.040 | Confirm whether the owner has filed an election or rescission; verify project stage before relying on AS standards. |
| Boundary maps and specific PTOD/S overlay maps | Standards apply only inside mapped boundaries; boundaries can contain parcel‑level exceptions § 18.34.060; § 18.12.100(c) | Obtain official GIS/Zoning Map layers from the City; verify exact parcel inclusion. Verify with the jurisdiction. |
| Interaction with underlying zoning | Some overlays replace the underlying zone when elected (AS1/AS2) while others modify only certain standards (S, PTOD) § 18.60.050; § 18.12.100; § 18.34.040 | Confirm whether the overlay displaces or supplements base zoning for your parcel. |
| Nonconforming uses and conversion rules | Applying a combining district may subject legal nonconforming uses to new overlay standards § 18.34.070 | If your site has legal nonconforming uses, check how overlay application alters those rights. |
| Site‑specific Development Agreement terms | AS districts reference the Stanford Development Agreement and “2003 Rules” for definitions and procedures § 18.60.020 – .040 | Review the Development Agreement and any recorded property restrictions; verify affect on project entitlements. |
Plain‑English Summary
Palo Alto’s overlays/combining districts are special, map‑based rules that can change what you can build on a parcel. Some are small‑scale neighborhood overlays (the Single‑Story (S) combining district that caps height at 17 ft) while others are site‑specific, optional standards for Stanford lands (AS1/AS2/AS3), and still others like PTOD or HW control uses and intensity near transit or for hazardous facilities. Always check the zoning map and the specific § of Title 18 that lists the overlay standards before you design—verify parcel inclusion and whether the overlay replaces or supplements the base zoning. See the city’s Development Standards, parking, Design Review, and ADUs pages for related requirements and the California Building Standards Code for building rules.
Source References
- § 18.60.010 – § 18.60.070 (Alternative Development Standards for Stanford lands — AS1/AS2/AS3): § 18.60.010, § 18.60.030, § 18.60.040, § 18.60.050, § 18.60.060, § 18.60.070.
- § 18.12.100 (Single‑Story (S) Combining District — applicability, standards, creation/removal procedures).
- § 18.34.030 – § 18.34.070 (PTOD combining district land uses, standards, review/rezoning procedures).
- Chapter 18.62 (Hazardous waste facility combining district — § 18.62.010 – § 18.62.060).
- Cross‑references and combining district mentions in other district chapters (e.g., CC/CN/CS mixed‑use rules; special purpose districts Chapter 18.28) § 18.16.060, § 18.28.050.
If you need the exact unabridged ordinance text or the official map layers for any of these overlays, verify with Palo Alto Planning & Development Services or check the City’s official municipal code and GIS zoning maps. Verify parcel‑specific application with the City.
Sources
Retrieved passages
- Palo Alto Zoning Code (Chapter 18.60) High relevance
- Palo Alto Zoning Code (section shall) High relevance
- Palo Alto Zoning Code (Chapter 18.64) High relevance
- Palo Alto Zoning Code (Section 6.4.2) High relevance
- Palo Alto Zoning Code (Chapter 18.98.) High relevance
- Palo Alto Zoning Code (Chapter 18.12) High relevance
- Palo Alto Zoning Code (Section 18.12.040) High relevance
- Palo Alto Zoning Code (§ 2) High relevance
Cited sections
- **§ 18.60.010 – § 18.60.070** (Alternative Development Standards for Stanford lands — AS1/AS2/AS3): **§ 18.60.010**, **§ 18.60.030**, **§ 18.60.040**, **§ 18.60.050**, **§ 18.60.060**, **§ 18.60.070**. (§ 18.60.010)
- **§ 18.12.100** (Single‑Story (S) Combining District — applicability, standards, creation/removal procedures). (§ 18.12.100)
- **§ 18.34.030 – § 18.34.070** (PTOD combining district land uses, standards, review/rezoning procedures). (§ 18.34.030)
- **Chapter 18.62** (Hazardous waste facility combining district — **§ 18.62.010 – § 18.62.060**). (Chapter 18.62)
- Cross‑references and combining district mentions in other district chapters (e.g., CC/CN/CS mixed‑use rules; special purpose districts Chapter 18.28) **§ 18.16.060**, **§ 18.28.050**. (Chapter 18.28)
- PaloAlto_ZoningCode.md
Frequently asked questions
What is an overlay/combining district in Palo Alto and how is it different from base zoning?
An overlay or combining district is a map‑based set of rules that sits on top of the underlying zoning to modify permitted uses, development standards, or procedures for parcels in the mapped area. Some overlays (like certain AS districts) can replace the underlying zoning if elected; others (like the Single‑Story (S) or PTOD) modify specific development standards while the base zone continues to apply. See § 18.60.040, § 18.12.100, and § 18.34.040.
What can I build on a parcel in the AS2 (Upper California) overlay?
If the landowner elects AS2, the Upper California Site may be developed for single‑family, two‑family, or multiple‑family residential uses, with child care permitted and below‑market‑rate housing obligations per the Development Agreement; the 20 ft California Avenue frontage setback is specified in the AS2 standards § 18.60.060. Confirm whether the owner has elected AS2 for the parcel.
What are the Single‑Story (S) overlay key limits and how is it created?
Within an S combining district (applied only to R‑1 zones) the maximum height is 17 ft (up to 20 ft in some flood areas) and only one habitable floor is allowed; creation/removal requires an owner petition with signatures from 70% of included properties (or 60% when deed restrictions apply) and processing under Chapter 18.98 § 18.12.100(c).
Do overlays change parking or design review requirements?
Overlays can alter site layout and permitted intensity, which affects parking requirements and can trigger Design Review. The PTOD, for example, ties rezoning to ARB major architectural review after rezoning § 18.34.060(d); always check the overlay chapter and the city’s parking and Design Review rules for project‑level requirements.
Can nonconforming uses be affected when an overlay is applied?
Yes. Owners of sites with legal nonconforming uses can request application of a combining district (e.g., PTOD) to their site, and, if rezoned, the use/facility would then be subject to the overlay’s standards § 18.34.070. That may change how the use is regulated.
Are hazardous waste facilities allowed anywhere under overlay rules?
No. New or expanded hazardous waste facilities are prohibited unless sited in a designated Hazardous Waste (HW) combining district and must comply with the Santa Clara County Hazardous Waste Management Plan siting criteria described in Chapter 18.62 § 18.62.010–.060.
If a property is inside a PTOD, what is the typical rezoning and review path?
Rezoning to PTOD is processed under Chapter 18.80 (map amendments) with Planning & Transportation Commission and City Council review; once rezoned the project typically goes to major architectural review by the ARB per § 18.34.060 and § 18.34.040(d).
Who decides whether a Stanford site uses the AS standards and when can that decision be reversed?
Stanford (the property‑owner referenced in the ordinance) may elect whether to be subject to AS1 or AS2 (or neither) for eligible sites; the election is filed at the time of discretionary review and may be rescinded any time prior to building permit issuance § 18.60.030–.040. Verify the recorded election on a parcel‑specific basis.
How do I know if an overlay displaces the underlying zoning or just modifies it?
Check the overlay’s Chapter: AS1/AS2 explicitly say the underlying zoning “does not apply” if the owner elects the AS district; other overlays like the Single‑Story (S) combining district state that their regulations apply “in lieu of” certain comparable provisions while other base rules still govern § 18.60.050; § 18.12.100. If uncertain, verify with the jurisdiction.
How are neighborhood boundaries and signature thresholds determined for an S overlay application?
An S overlay application must include a map with boundaries defined by natural or man‑made features and a signature list showing support by 70% of included properties (or 60% in some deed‑restricted situations); the area proposed must be of prevailing single‑story character (at least 80% single‑story) § 18.12.100(c)(2)(B)–(C).
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