Four Corners Townhome Project Inclusionary Housing Alternative Compliance

The City of East Palo Alto has approved an alternative compliance option for the Four Corners Townhome Project, a 106-unit development located at 2400 University Avenue, requiring the provision of 11 on-site affordable housing units targeted to moderate-income households earning up to 120% of the Area Median Income. This approach replaces standard inclusionary housing requirements with a locally negotiated compliance mechanism, validated through a categorical exemption under CEQA Guidelines Sections 15378(b)(4) and (5), which classify the action as a non-physical governmental administrative decision with no significant environmental impact. The project, managed by Four Corners EPA Property Owner, LLC d/b/a Sand Hill Property Company, operates under the oversight of the City of East Palo Alto, with Associate Planner Michelle Huang serving as the primary point of contact for administrative matters. No formal contract clauses, solicitation numbers, pricing data, or procurement-specific terms were identified in the documentation, indicating this is not a traditional procurement transaction but rather an administrative approval of housing policy compliance under state environmental law. The delivery and performance occur entirely at the project site in East Palo Alto, California, with acceptance responsibilities resting with the city as the lead agency. While there is no defined period of performance, invoicing mechanism, payment office, or contract value provided, the compliance obligation is clear: 11 units must be sold at affordable prices to eligible households. The documentation lacks standard acquisition elements such as evaluation factors, representations, certifications, special requirements, or submission instructions, underscoring that this action is a regulatory determination rather than a competitively awarded contract.