80 Willow Rd. (Willow Park)

80-Willow-Rd-image

The City continues to process the Willow Park development application at 80 Willow Road. The Applicant (N17 Development representing Willow Park LLC) is pursuing the Willow Park project through multiple avenues, including, but not limited to SB 330, the "Builder's Remedy," and AB 2011. View a Feb. 13, 2026 summary overview of the applicant’s proposed project and the City’s review.

The proposed project is located on a 6.7-acre site at 80 Willow Road in the Linfield Oaks neighborhood (Location Map). The project proposes demolition of all existing structures to construct a new mixed-use development with approximately 665 residential units, 332,000 square feet of office, 17,000 square feet of retail, and 164,000 square feet of hotel (130 rooms). The proposed preschool building (approximately 3,000 square feet) would be 22 feet tall and the other three proposed buildings would range from 301-458 feet tall. The existing site was the former headquarters of Sunset Magazine and was deemed eligible for the National Register of Historic Places and is listed in the California Register of Historical Resources.

Attorney General’s notice of violation

On July 29, 2026, the California Attorney General’s (“AG”) office sent the City written notice pursuant to AB 712 (Government Code section 65914.2) regarding the 80 Willow project. The AG notice states the City has violated AB 2011 and the Housing Accountability Act in its processing of the project. AB 712 requires courts to penalize cities that fail to follow state housing laws if the AG warns the city that it violated such laws.

City response to Attorney General's notice of violation

On Oct. 1, 2026, the City sent a response to the Attorney General's letter to the City from July 29. The City asserts it has processed the development application for 80 Willow Road in accordance with all applicable state laws.

Closed session report out - Sept. 29, 2026

Report out by City Attorney Nira Doherty
The City Council has authorized me to provide this report out of closed session:

After extensive deliberation, the City Council has carefully considered the Attorney General’s July 29, 2026, notice regarding the 80 Willow Rd. project. The Attorney General has concluded that the project is consistent with the requirements of AB 2011 (the Affordable Housing and High Roads Jobs Act of 2022) and, as currently proposed, satisfies the definition of a builder’s remedy project. This would mean that the City would be required to approve the project as proposed without any environmental review. The Attorney General has further reached conclusions regarding the City’s application processing fees, though without any factual basis to support them. 

The City Council respectfully disagrees with the Attorney General’s analysis. It believes the Attorney General’s conclusions are incorrectly reasoned and contrary to law. Prior to and since receiving the Attorney General’s notice, the City, with the assistance of legal counsel, has carefully and exhaustively analyzed all of the issues set forth in the Attorney General’s letter. The City has taken thorough, good faith positions on each of the issues raised by the Attorney General; further, each of the City’s positions is amply supported by applicable law. For that reason, the Council simply does not agree that State law requires approval of the 80 Willow Rd. project under the terms set forth in the AG’s letter. 

The Council recognizes that the financial penalties the Attorney General and Applicant have threatened could impose severe consequences on the City. The City Council considers the threat of those penalties as deeply unfair and extremely punitive. Even so, the Council maintains that the Attorney General’s position is inconsistent with the Legislature’s intent, and that the Attorney General is wielding the threat of those extraordinary penalties to coerce the City into action the City, in the utmost good faith, believes the law does not require.

Report out by Mayor Betsy Nash
The City Council is united in its position that the Attorney General has incorrectly directed the City to approve the 80 Willow Rd. project under the terms of AB 2011. The AG issued its opinion without having the benefit of the City’s extensive knowledge of the property and the history of the development application, and without once inquiring with the City about the background of the application.

The Council strongly opposes approval of the project under the terms in the AG’s letter. This massive commercial development would severely compound infrastructure challenges in Menlo Park, endanger emergency services response times, and exacerbate the existing jobs/housing imbalance. The project does not deliver the housing that Menlo Park needs, contrary to the very purpose of the builder’s remedy law. In addition, questions have been raised of potential illegality, corruption, and national security around the property owner – as outlined in Representative Liccardo’s September 23, 2026, letter to U.S. Treasury Secretary Bessent. Finally, we need to be clear with residents that the City Council does not take this position lightly, but rather it does so because we feel Menlo Park is being ill-served by the State’s inappropriate position on various laws. The City Council believes it is important to get this right even if there are financial consequences and service impacts for the city that may be triggered by our effort to vindicate our rights and protect the Menlo Park community.

Applicant’s lawsuit

On Oct. 2, 2026, N17 Development filed a complaint and petition for writ of mandate (lawsuit) alleging the City violated State housing laws by not processing its project pursuant to AB 2011 and did not afford it certain protections under the builder’s remedy law.  The lawsuit invokes the penalties set forth in the Attorney General’s July 29 notice.

The following statutory deadlines apply to the lawsuit’s timing pursuant to new laws which expedite writ proceedings alleging violations of State housing laws.  The dates are subject to change.

  • Oct. 20: Administrative record certified
  • Nov. 16 or 19: Hearing
  • Dec. 19: Decision issued by the Court 

What are the next steps?

The City will continue to: 1) process the development application and respond to the applicant’s assertions, 2) follow environmental review requirements pursuant to the California Environmental Quality Act (CEQA) unless the application demonstrates it is exempt, and 3) keep the community informed of project updates through this webpage and email updates (subscribe below).

The project is subject to environmental review pursuant to CEQA unless exempt through other processes (such as AB 2011). In May 2025, the City approved a professional services contract for LSA Associates to perform the required environmental analysis. The environmental review work has not begun and is pending the applicant’s deposit of funds for the consultant to begin the work. Please refer to the “Frequently asked questions” section below for additional information, attention to the “What is the environmental review (CEQA) process” subsection.

Are the project plans available for review?

View site plan and massing diagrams(PDF, 1MB)

Pursuant to State law, the City is limited in its availability to publicly post architectural drawings without architect permission. Members of the public may view the application materials, including architectural drawings, in person at City Hall. Appointments are encouraged to view the materials in person. Appointments with the Planning Division can be made online at menlopark.gov/appointment.

To receive updates about the project, please subscribe below.

Timeline

Select events in the project history are listed below, beginning with the most recent event.

  • On Aug. 3, 2026, the developer's attorney sent the City written notice  expressing the intent to commence legal action against the City.

  • On July 29, 2026, the California Attorney General’s (“AG”) office sent the City written notice pursuant to AB 712 (Government Code section 65914.2) regarding the 80 Willow project.
  • On April 13, 2026, the City deemed the application inconsistent with multiple development standards. See additional information under the “Frequently asked questions” drop down menu below (attention to “What does a consistency review mean?”).
    - Consistency review letter(PDF, 1MB)

  • On April 6, 2026, the Applicant submitted materials to support their assertion of application processing under AB 2011. The City will review the materials and issue a determination.

  • On Feb. 12, 2026, the Applicant resubmitted the formal development application in response to the City’s Jan. 22, 2026 determination.
  • On Nov. 19 and Dec. 24, 2025, the Applicant submitted additional materials to support their assertion of application processing under AB 2011. On Dec. 18, 2025 and Jan. 22, 2026, the City issued determinations that the application remains ineligible for streamlined processing under AB 2011 and continues to evaluate the assertion of application filing under the Builder’s Remedy.
    - AB 2011 determination - Dec. 18, 2025(PDF, 146KB)
    - AB 2011 determination - Jan. 22, 2026(PDF, 174KB)

  • On Nov. 7, 2025, the City deemed the application inconsistent with multiple development standards. The City also determined that the application is not eligible for streamlined processing under AB 2011 and continues to evaluate the assertion of application filing under the Builder’s Remedy. See additional information under the “Frequently asked questions” drop down menu below.
    - Consistency review letter(PDF, 345KB)
    - AB 2011 determination(PDF, 817KB)

  • On Oct. 10, 2025, the Applicant resubmitted the formal development application in response to the City’s May 6, 2025 determination.

  • On May 13, 2025, the City Council approved a professional services contract with LSA Associates to perform the required environmental analysis for the development proposal. See additional information about the CEQA process under the “Frequently asked questions” dropdown below (attention to “What is the environmental review (CEQA) process?”).
    -  Staff report(PDF, 52MB)
    -  Video

  • On May 6, 2025, the City deemed the application inconsistent with multiple development standards. See additional information under the “Frequently asked questions” drop down menu below (attention to “What does a consistency review mean?”).
    - Consistency review letter(PDF, 580KB)

  • On Mar. 7 and 19, 2025, the Applicant resubmitted the formal development application in response to the City’s Jan. 13, 2025 determination.

  • On Feb. 28, 2025, the City received a total of six scopes of work and budget proposals from environmental consultant firms in response to the request for proposals (RFP). See additional information about the CEQA process under the “Frequently asked questions” drop down menu below (attention to “What is the environmental review (CEQA) process?”).

  • On Jan. 24, 2025, the City issued a Request for Proposal (RFP)(PDF, 2MB) for CEQA consultant services. See additional information about the CEQA process under the “Frequently asked questions” drop down menu below (attention to “What is the environmental review (CEQA) process?”).

  • On Jan. 13, 2025, the City deemed the application inconsistent with multiple development standards. See additional information under the “Frequently asked questions” drop down menu below (attention to “What does a consistency review mean?”).
    - Consistency review letter(PDF, 265KB)

  • On Nov. 14, 2024, the City deemed the application complete. See additional information under the “Frequently asked questions” drop down menu below (attention to “What does a complete application mean?”).
    - Completeness review letter(PDF, 197KB)

  • On Oct. 16, 2024, the Applicant resubmitted the formal development application. 

  • On Oct. 11, 2024, the City deemed the application incomplete due to required items missing from the application.
    - Completeness review letter(PDF, 2MB)

  • On Sept. 12, 2024, the Applicant resubmitted the formal development application.

  • On June 22, 2024, the City deemed the application incomplete due to required items missing from the application.
    - Completeness review letter(PDF, 1MB)
    - AB 2011 determination(PDF, 130KB)

  • On May 24, 2024, the Applicant submitted the formal development application. 

  • On Dec. 7, 2023, the Applicant submitted a preliminary application.

Frequently asked questions

What does a complete application mean?

The City deemed the application complete on November 14, 2024 as all required items have been submitted per established City and Senate Bill 330 (SB 330 or Housing Crisis Act of 2019) guidelines. SB 330 allows a preliminary application process and streamlined review for eligible housing development projects.

The determination of application completeness begins the next phase of consistency review.

What does a consistency review mean?

The City reviewed the project for consistency with applicable development standards. The Housing Accountability Act requires the City to identify a housing development project’s inconsistency with objective development standards.  A determination of inconsistency does not amount to a denial of the project.

On Jan. 13, 2025; May 6, 2025; Nov. 7, 2025; Feb. 12, 2026; and April 13, 2026, the City found the application to be inconsistent with multiple City development standards.

What is the environmental review (CEQA) process?

The project is subject to review pursuant to the California Environmental Quality Act (CEQA). 

As a first step, the CEQA consultant prepares an Initial Study (IS) that serves as a preliminary analysis to determine the relative environmental impacts associated with a proposed project. It is designed as a measuring mechanism to determine if a project could have a significant adverse effect on the environment.

If the IS results show that mitigation would not be possible or feasible for any of the topics, or would still result in a significant environmental impact, preparation of an Environmental Impact Report (EIR) is required. If mitigation is possible or feasible, a mitigated negative declaration may be prepared. If the IS results show no potential for environmental impacts, a negative declaration may be prepared.

Consultant Selection – Request for Proposals (RFP)

On May 13, 2025, the City Council approved a professional services contract with LSA Associates to perform the required environmental analysis for the development proposal.

If the project is subject to environmental review, the environmental review typically covers a number of topic areas in relation to the physical environment, such as:

  • Aesthetics
  • Agriculture and Forestry Resources
  • Air Quality
  • Biological Resources
  • Cultural Resources
  • Geology and Soils
  • Greenhouse Gas Emissions
  • Hazards and Hazardous Materials
  • Hydrology and Water Quality
  • Land Use and Planning
  • Mineral Resources
  • Noise and Vibration
  • Population, Housing, and Employment
  • Public Services and Recreation
  • Transportation and Traffic
  • Utilities and Service Systems
Public Participation and Timeline

Public participation is an essential part of the CEQA process. The City will issue and publicize notices to announce various milestones in the CEQA process such as:

  • Consultant Selection – On May 13, 2025, the City Council approved a professional services contract with LSA Associates to perform the required environmental analysis for the development proposal.
  • If it is determined that an EIR must be prepared:
    • Notice of Preparation and EIR Scoping Session – This notice confirms the preparation of an EIR and announces a public scoping session. An EIR scoping session provides an opportunity early in the environmental review process for the Planning Commission and the public to comment on specific topics that they believe should be addressed in the environmental analysis.
    • Notice of Availability of Draft EIR – This notice announces the availability of the Draft EIR document and begins a public review and comment period.
    • Notice of Release of Final FEIR – This notice announces the availability of the Final EIR document, which may contain additional information about potential environmental impacts and responds to substantive comments received during the public comment period.
    • Public hearings with the Planning Commission and City Council will be held to evaluate/certify the environmental review documents along with review for the project application itself. A summary timeline of environmental review milestones will be developed by the City and the CEQA consultant and posted to this webpage. Please check back and subscribe to the project email list for updates.

Does the property have a special historical status?

On June 24, 2025, the federal Keeper of the National Register of Historic Places (National Register) determined that the property is eligible for the National Register. As a result of being determined eligible for the National Register, the property has also been listed in the California Register of Historical Resources (California Register).

What is “Builder’s Remedy”?

California Government Code § 65589.5(d)(5) of the Housing Accountability Act (HAA), provides that a local agency shall not disapprove a housing development project for very low-, low-, or moderate-income households, or an emergency shelter, or condition approval in a manner that renders the housing development project infeasible, based on the project’s inconsistency with zoning and General Plan standards, if the local agency had not timely adopted a “substantially compliant” housing element.

Visit the Builder’s Remedy webpage to learn more.

What is AB 2011?

AB 2011 (as amended by AB 2243 and AB 893) streamlines housing development in certain commercial zones in California. It requires ministerial approval of qualifying housing development projects if the project meets prescriptive project, site, affordability, density and labor standards. Projects subject to AB 2011 are exempt from CEQA.

The City has determined the project is ineligible for streamlined review pursuant to AB 2011. The applicant has the opportunity to respond to the City’s determination.

Notice of challenged conduct

On Nov. 19, 2025(PDF, 258KB), the applicant submitted a letter challenging the City’s conduct related to the City’s prior determinations that the project is ineligible for AB 2011. Pursuant to State law, the City must respond to the applicant’s challenged-conduct correspondence between January 18, 2026 and February 17, 2026.

On Feb. 10, 2026(PDF, 152KB), the City issued a challenged conduct response letter to detail how the City’s actions have not “disapproved a housing development project.” 

 

Contact us

Calvin Chan
Senior Planner
Email

650-330-6763

Location

80 Willow Rd., Menlo Park, CA 94025  View map

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