Agenda packet — East Palo Alto City Council, December 16, 2025

EAST PALO ALTO CITY COUNCIL

REGULAR SESSION AMENDED AGENDA
Tuesday, December 16, 2025, 6:30 PM
EPA Government Center
2415 University Avenue, First Floor
East Palo Alto, CA 94303
NOTICE
This meeting will be held virtually and in- person at the Council Chambers located on 2415 University Ave, First Floor East Palo Alto, CA 94303. The virtual portion of this City Council meeting will be conducted in accordance with City of East Palo Alto Resolution adopted pursuant to Assembly Bill 361.

The public may participate in the City Council Meeting via Zoom Meeting or by attending inperson in the Council Chambers at 2415 University Ave, First Floor East Palo Alto, CA 94303.

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International numbers available: https://zoom.us/u/aMWYF4KT East Palo Alto City Council December 16, 2025 Agenda
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1. CALL TO ORDER AND ROLL CALL

2. APPROVAL OF THE AGENDA

3. APPROVAL OF CONSENT CALENDAR

3.1 Monthly Cash Treasury Report for October 2025
Recommendation: Accept and file the Cash Treasury Report for the month of October 2025

3.2 Annual Development Impact Fee Report (AB 1600 Report) Recommendation:

Adopt a resolution:

1. Accepting the Annual Development Impact Fee Report (AB 1600 Report) for Fiscal Year 2024-25; and

2. Finding that the proposed action does not constitute a “project” with the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment.

3.3 Agreement with Street Level Advisors and the Community Planning Collaborative in Updating the Inclusionary Housing Ordinance (IHO) and Guidelines
Recommendation: Adopt a resolution:

1. Authorizing the City Manager to award, negotiate and execute a two-year agreement with Street Level Advisors in partnership with Community Planning Collaborative , in form approved by the City Attorney, in an amount not-to-exceed $75,000, and with two one-year extensions at the sole discretion of the City Manager to provide project management and the updating of the Inclusionary Housing Ordinance (“IHO”) and guidelines; and

3.4 City Council Meeting Minutes
Recommendation:

Adopt December 5, 2025, minutes.

East Palo Alto City Council December 16, 2025 Agenda
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4. CLOSED SESSION

5. PUBLIC COMMENT

6. INFORMATIONAL REPORTS

7. SPECIAL PRESENTATIONS

7.1 Northern California Carpenters Union Special Presentation

8. PUBLIC HEARINGS

9. POLICY AND ACTION

9.1 Resolution Modifying Regular City Council Meeting Start Times to 5:30 pm
Recommendation: Consider adopting a resolution establishing regular City Council meetings on the first and third Tuesdays of each month with a one hour earlier start time of 5:30 pm.

9.2 Internal Control Policy
Recommendation:

Adopt a resolution:

1. Approving the City of East Palo Alto Internal Control Policy; and

2. Accepting implementation framework in response to the 2023-24 San Mateo County Civil Grand Jury Report “Assessing and Reporting Internal Controls”; and

3. Receiving the Internal Control Procedures Manual and Example Risk Register

9.3 Authorization to Award Agreement to LAZ Parking to Provide Parking Enforcement and Staffing Services
Recommendation:

1. Receive a presentation on the competitive procurement process leading to the recommendation to select LAZ Parking as the vendor to provide Parking Enforcement;

2. Provide staff direction on the preferred level of parking enforcement service (Baseline, Expanded, or Comprehensive 24-Hour
Coverage); and

3. Adopt a Resolution:
a. Authorizing the City Manager to award, negotiate and execute a five-year agreement with LAZ Parking, in a form approved by the East Palo Alto City Council December 16, 2025 Agenda
3 3
City Attorney, at the cost of the preferred level of parking enforcement service; and
b. Finding the proposed action does not constitute a “project” with the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(5) in that it is a governmental administrative activity that will not result in direct or indirect changes in the environment.

10. COUNCIL REPORTS

11. ADJOURNMENT
Upcoming meetings:

January 6, 2026 Regular Meeting Time TBD
January 20, 2026 Regular Meeting Time TBD
February 3, 2026 Regular Meeting Time TBD
This AGENDA is posted in accordance with Government Code Section 54954.2(a) This Notice of Availability of Public Records: All public records relating to an open session item which are not exempt from disclosure pursuant to the Public Records Act, that are distributed to the majority of the City Council will be available for public inspection at the City Clerk’s Office, 2415 University Avenue, East Palo Alto, CA at the same time that the public records are distributed or made available to the City Council. Such documents may also be available on the East Palo Alto website www.cityofepa.org subject to staff’s ability to post the documents prior to the meeting. Information may be obtained by calling (650) 853-3100.

The City Council meeting packet may be reviewed by the public in the Library or the City Clerk's Office. Any writings or documents pertaining to an open session item provided to a majority of the City Council less than 72 hours prior to the meeting, shall be made available for public inspection at the front counter at the City Clerk's Office, 2ND Floor, City Hall, 2415 University Avenue, East Palo Alto, California 94303 during normal business hours. Information distributed to the Council at the Council meeting becomes part of the public record. A copy of written material, pictures, etc. should be provided for this purpose.

East Palo Alto City Council Chambers is ADA compliant. Requests for disability related modifications or accommodations, aids or services may be made by a person with a disability to the City Clerk's office at (650) 853-3127 no less than 72 hours prior to the meeting as required by Section 202 of the Americans with Disabilities Act of 1990 and the federal rules and regulations adopted in implementation thereof.

DECLARATION OF POSTING
This Notice is posted in accordance with Government Code §54954.2(a) or §54956. Members of the public can view electronic agendas and staff reports by accessing the City website. Under penalty of perjury, this Agenda was posted to the public at least 72 hours prior to the meeting.

POSTED: December 5, 2025
AMENDED: December 12, 2025
ATTEST:

James Colin
City Clerk
East Palo Alto City Council December 16, 2025 Agenda
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CONSENT ITEM 3.1

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: December 16, 2025
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Tomohito Oku, Finance Director
Jessica Y Caballero, Financial Services Manager
Esther Aguirre, Senior Accountant
SUBJECT: Monthly Cash Treasury Report for October 2025
Recommendation
Accept and file the Cash Treasury Report for the month of October 2025.

Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:

Priority: Governance, Organizational Strength, and Fiscal Sustainability Background
Pursuant to Section 53646 of the Government Code of the State of California, the City Treasurer may submit a quarterly report to the City Council regarding the funds and investments of the City. Further, City Investment Policy Section XVIII requires monthly reporting of investment transactions, as specified. Because the City participates in State and County investments pools and does not independently broker or engage outside investment advisors to transact investments, the monthly reporting provides a snapshot of overall cash receipts, transfers, and disbursements.

Analysis
The Monthly Cash Treasury Report (“Report”) covers cash and investments of the City in the four cash and investment accounts: Wells Fargo Bank, San Mateo County Pool, California State Local Agency Investment Fund, and the California Asset Management Program (CAMP). The 5 CONSENT ITEM 3.1
Report does not include petty cash, or the California State Community Infrastructure Program (SCIP) bond proceeds held by a trustee in the name of the City. For investment purposes, City cash is pooled, except for bond proceeds held by a trustee. The City does not have, nor is it legally required to have, separate bank accounts for each individual fund. However, all cash is segregated in the City’s accounting records. Monthly cash transactions for the monthly period ending October 31, 2025, are as follows:

The Wells Fargo cash balance reflects the book value balance (i.e., total outstanding checks not cashed are deducted from the account balance). The month-to-date cash and investment balance increased by approximately $5.8M compared to the balance as of September 30, 2025.

October receipts totaled approximately $9.5M, consisting primarily of the SMCTA Reimbursement for the University 101 Overcrossing ($7M), FY 2025–26 Unsecured Tax Apportionment ($0.6M), Other tax distributions ($0.4M), Four Seasons Hotel Transient Occupancy Tax ($0.3M), Veolia payment ($0.2M), Trash Capture Device Project development reimbursement ($0.2M), and other various receipts..

October disbursements totaled approximately $4.5M, consisting primarily of payroll costs with three pay cycles ($1.6M), Recology Q1 refuse collection and recycling services ($0.8M), West Sanitary District maintenance services ($0.1M), Kaiser Foundation medical contributions ($0.1M), and other recurring operating expenditures.

The table below reflects recent treasury yield comparisons up to five-year notes since that is the maximum maturity the City may invest1:

Local Agency Investment Fund (LAIF) average monthly effective yields were 4.150% in October compared to 4.212% in September 2025. San Mateo County monthly gross earnings for October were 4.156% compared to 3.887% in September 2025. The estimated County Pool earnings for FY 25-26 are 3.75%. As of October 2025, the current annualized yield for California Asset Management Program (CAMP) is 4.26% compared to 4.36% in September 2025.

Staff believes the City has investment liquidity and anticipated revenues to meet the City’s anticipated expenditure requirements for the ensuing six months. The following table shows a

1 Daily US Treasury Yield Curve. Treasury.gov
6 CONSENT ITEM 3.1
breakdown of cash and investment balance by fund type.

The deposit market value totals $149,282,974 including an unrealized gain2 of $372,920, reflecting treasury yields during the calendar year. All except for the General Fund balance is restricted by either City Council or external parties for specific purposes. Unrestricted cash and investment balance under General Fund ($41,778,648) may be used at Council discretion.

Fiscal Impact
There is no fiscal impact for this item. This report is informational.

Public Notice
The public was provided notice by making the agenda and report available on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto.

Environmental
The action being considered by the City Council is exempt from the California Environmental Quality Act (CEQA) because it is not a “project” pursuant to 15378(b)(4) because it is a fiscal activity which does not involve any commitment to any specific project which may result in a potentially significant impact on the environment.

Government Code § 84308
Applicability of Levine Act: No, as the proposed action does not involve an entitlement.

Analysis of Levine Act Compliance: Not applicable.

2 Investment Fair Market Value (FMV) factor is provided on a quarterly basis. Thus, as of September 30, 2025, FMV factor is used to calculate Unrealized Gain/(Loss) on Investments. 7 CONSENT ITEM 3.2

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: December 16, 2025
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Tomohito Oku, Finance Director
Jessica Y Caballero, Financial Services Manager
SUBJECT: Annual Development Impact Fee Report (AB 1600 Report) Recommendation
Adopt a resolution:

1. Accepting the Annual Development Impact Fee Report (AB 1600 Report) for Fiscal Year 2024-25; and

Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:

Priority: Governance, Organizational Strength, and Fiscal Sustainability Background
State law authorizes the City of East Palo Alto to collect development impact fees from new development. The City manages a limited number of these fee programs, which fund capital infrastructure projects associated with development impacts. Development impact fees are generally paid at the time a building permit is issued.

California Government Code Section 66006(b) (“AB 1600”) outlines the reporting requirements for local agencies that impose impact fees on new development. Each year, for every separate 8 CONSENT ITEM 3.2
fund established for the collection and expenditure of these fees, the City must make specific information publicly available within 180 days of the fiscal year’s end. This reporting is commonly referred to as the AB 1600 Report. The City’s AB 1600 Report for the fiscal year ended June 30, 2025 (Attachment 1) fulfills the requirements of Section 66006(b) and provides an overview of how restricted development impact funds are collected and utilized.

Analysis
Historically, the City primarily collected fees through redevelopment agency agreements, statutory development agreements, or certain in-lieu fees considered zoning-related use restrictions. These fees are not subject to AB 1600 reporting requirements. Since 2014, the City has adopted Affordable Housing Commercial Linkage fees, Water Capacity fees, and fees related to storm drainage, transportation, parks, and public facilities.

The attached AB 1600 Report provides a detailed analysis of the status of each fee required to be reported for the fiscal year ended June 30, 2025.

As required under Government Code Section 66001(d), the City has evaluated the unexpended balance of its Public Facilities Development Impact Fee (DIF) fund that has remained on deposit for more than five years. As of June 30, 2025, the fund includes an unexpended balance of $1,408 that is reserved for the Police Department Facility Improvement Project. The purpose of this fee—enhancing public safety facilities—maintains a reasonable relationship to the improvements for which it was collected. The total project cost is estimated at approximately $400,000, with the remaining funding to be provided through the City’s local Capital Improvement Program (CIP) fund. The City deposited the necessary CIP funds and commenced the project in November 2025.

Additionally, AB 1600 mandates that the report be made available to the public at least 15 days prior to Council review and acceptance. In compliance, the City posted the AB 1600 Report on its website on December 1, 2025.

Fiscal Impact
There is no fiscal impact for this item.

Public Notice
The public was provided notice by making the agenda and report available on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto.

The AB 1600 Report has also been made available to the public on the City’s website as of December 1, 2025.

Government Code § 84308
Applicability of Levine Act: No, as the proposed action does not involve an entitlement.

Analysis of Levine Act Compliance: Not applicable.

Attachments

1. FY 2024-25 AB 1600 Report

2. Resolution
10 Fiscal Year Ended June 30, 2025
Development
Impact Fee Report
City of East Palo Alto, CA
11 This Page is Intentionally Blank
12 Development
Impact
Fee Report
Table of Contents
TRANSMITTAL LETTER .................................................................................................................... 3 LEGAL REQUIREMENTS FOR DEVELOPMENT IMPACT FEE REPORTING ......................................................... 4 DESCRIPTION OF DEVELOPMENT IMPACT FEES ..................................................................................... 6 FY 2023-24 FEE SCHEDULE ............................................................................................................ 8 FUND BALANCES ......................................................................................................................... 10 COLLECTION AND USE .................................................................................................................. 11 PARKS AND TRAILS FEES ............................................................................................................ 11 PUBLIC FACILITIES FEES ............................................................................................................. 12 TRANSPORTATION INFRASTRUCTURE FEES ..................................................................................... 13 STORM DRAINAGE INSIDE RBD FEES ............................................................................................ 14 STORM DRAINAGE OUTSIDE RBD FEES ......................................................................................... 15 WATER CAPACITY FEE – BUY IN COMPONENT ................................................................................ 16 WATER CAPACITY FEE – SUPPLY COMPONENT ............................................................................... 17 AFFORDABLE HOUSING IMPACT FEES ........................................................................................... 18 13 3
Transmittal Letter
December 1, 2025
Honorable Members of the City Council
Citizens of East Palo Alto, California
State law requires any local agency that imposes development impact fees to prepare an annual report providing specific information about those fees. As such, in accordance with the provisions of the California Government Code Section 66006 (b) and 66001 (d), as amended by Assembly Bill (AB) 518 and Senate Bill (SB) 1693, we submit the Development Impact Fee (DIF) Report for the City of East Palo Alto, California for the fiscal year (FY) ended June 30, 2025.

DIFs are charged by local governmental agencies in connection with the approval of development projects. The purpose of these fees is to defray all or a portion of the cost of public facilities related to the development project. The legal requirements for enactment of a DIF program are set forth in Government Code Sections §66000 - 66025 (the "Mitigation Fee Act"). The Mitigation Fee Act is commonly referred as “AB 1600”.

Previously, the City primarily collected fees pursuant to redevelopment agency agreements or statutory development agreements or collected certain in-lieu fees considered zoning-related use restrictions; such fees and collections are not subject to AB 1600 reporting requirements. Since 2014, the City has adopted Affordable Housing Commercial Linkage fees, Water Capacity fees, and fees related to storm drainage, transportation, parks, and public facilities. It is notable the City imposed a two-year water connection moratorium effectively halting development from July 2016 to August 2018.

State law requires the City prepare and make available to the public the DIF Report within 180 days after the last day of each fiscal year. The City Council must consider the acceptance of the annual report at a regularly scheduled public meeting. The information must be made available to the public no fewer than fifteen days prior to the meeting. This report was filed with the City Clerk’s office and available for public review on December 1, 2025.

Respectfully submitted,
Tomohito Oku
Finance Director
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Legal Requirements for Development
Impact Fee Reporting
California Government Code Section 66006(b)
California Government Code Section 66006 (b) defines the specific reporting requirements for local agencies that impose AB 1600 impact fees on new development. Annually, for each separate fund established for the collection and expenditure of impact fees, the local agency shall, within 180 days after the last day of each fiscal year, make available to the public the information shown below for the most recent fiscal year. The applicable page numbers for the location where each item can be found in the report are provided for reference.
• A brief description of the type of fee in the account or fund. (Page 6) • The amount of the fee. (Page 8)
• The beginning and ending balance of the account or fund. (Page 10) • The amount collected and interest earned. (Page 10)
• An identification of each public improvement on which fees were expended and the amount of expenditures on each improvement. (Page 11)
• An identification of an approximate date by which the construction of the public improvement will commence if the local agency determines adequate funds have been collected to complete financing on an incomplete public improvement.
o Not applicable during FY 2024-25
• A description of each interfund transfer or loan made from the account or fund, including the public improvement on which the transferred or loaned fees will be expended, and, in the case of an interfund loan, the date on which the loan will be repaid and the rate of interest that the account or fund will receive on the loan.
o Not applicable during FY 2024-25
• The amount of refunds made due to adequate funds being collected to complete financing on incomplete public improvements, and the amount of reallocation of funds made due to administrative costs of refunding unexpended revenues exceeding the amount to be refunded. o Not applicable during FY 2024-25

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California Government Code Section 66001(d)
For all funds established for the collection and expenditure of DIFs, California Government Code Section 66001 (d) has additional requirements. For the fifth fiscal year following the first deposit into the fund and every five years thereafter, the local agency shall make the following findings with respect to that portion of the fund remaining unexpended, whether committed or uncommitted:
• Identify the purpose to which the fee is to be put.
• Demonstrate a reasonable relationship between the fee and purpose for which it is charged. • Identify all sources and amounts of funding anticipated to complete financing of incomplete improvements.
• Designate the approximate dates on which the funding is expected to be deposited into the appropriate account or fund.

As required under Government Code Section 66001(d), the City has evaluated the unexpended balance of its Public Facilities Development Impact Fee (DIF) fund that has remained on deposit for more than five years. As of June 30, 2025, the fund includes an unexpended balance of $1,408 that is reserved for the Police Department Facility Improvement Project. The purpose of this fee—enhancing public safety facilities—maintains a reasonable relationship to the improvements for which it was collected. The total project cost is estimated at approximately $400,000, with the remaining funding to be provided through the City’s local Capital Improvement Program (CIP) fund. The City anticipates depositing the necessary CIP funds and commencing the project in November 2025.

Capital Improvement Program (CIP)
The State of California Government Code Section 66002 states that local agencies that have developed a fee program may adopt a CIP indicating the approximate location, size, and timing of projects, plus an estimate for the cost of all facilities or improvements to be financed by fees. A formal CIP is recommended, at a minimum, as a five-year plan. The City produces a five-year CIP which helps to maintain and support the City’s General Plan as well as identify infrastructure needed to accommodate the planned development.

Establishment of Reasonable Relationship - Nexus Requirement Since FY 2014-15, the City has adopted the following DIF:

Affordable Housing Commercial Linkage (Update 2020)
Park and Trails, Transportation Infrastructure, Public Facilities, Storm Drainage (2019) Water Capacity (2019)
All fees were adopted following a Nexus Study demonstrating that the fees conform to AB 1600 requirements. Specifically, that there is a reasonable relationship between the infrastructure burdens of 16 6
development growth and the amount of fee. For information regarding impact fees and related studies please refer to the City’s website at: https://www.cityofepa.org/publicworks/page/city-widedevelopment-impact-fee-program.

Adjustments to the fees shall be made annually in accordance with the Engineering News Record Construction Cost Index. The Fee Nexus studies set forth the relationships between contemplated future development, facilities needed to serve future development and the estimated costs of those improvements based on the current General Plan for build-out. Comprehensive updates to the program are completed on an as-needed basis to ensure the program continues to reflect the appropriate fees in relation to updated costs.

Description of Development Impact Fees
• Affordable Housing Fee – Commercial Development
To enhance the public welfare by imposing a nonresidential development project Housing Impact Fee whereby developers of nonresidential development projects will mitigate the impacts of their projects on the need for affordable housing by contributing to the supply of housing for households with very low, low, and moderate incomes. Further, to implement the Housing Element by creating a mechanism to provide benefits to the community from new development in the form of affordable housing, thereby helping to meet the needs of all socioeconomic elements of the community as provided in the Housing Element. • Parks and Trails Fee
To provide adequate quality open space – through parks and trails – for the broader public health and quality of life of its citizens and workforce. In addition to providing opportunities for physical activity and interaction with the natural environment, additionally, this fee is to be used to conserve the natural open space resources in the city. The City aims to preserve and protect natural resources such as the Baylands, the shoreline, San Francisquito Creek, and significant tree stands through parks and trails projects.
• Public Facilities Fee
To provide a variety of public facilities, including public safety institutions such as police departments, educational amenities, and quality of life services such as libraries and community centers, and governance buildings such as City Hall.
• Transportation Infrastructure Fee
To provide public roads and multi-modal streetscape facilities. East Palo Alto aims to provide adequate roads for its citizens and workforce for general transportation and safety. In addition, 17 7
constructing sidewalks with street trees, street lighting, benches, and street furniture improves safety, sidewalk space, pedestrian aesthetics, and active transportation. • Storm Drainage Fee
To provide critical infrastructure to prevent flooding of streets during rain events. East Palo Alto aims to improve citywide storm drainage and provide adequate storm drainage for the City and for new development in the Ravenswood Business District (RBD), as stated in the policy directives of the RSP (Goal UTIL-3 and subsequent policies). Due to the specific storm drainage costs associated with the RBD, a specific fee is applied depending upon whether properties are located within the RBD or outside the RBD.
• Water Capacity Fee
To recover the costs of water system infrastructure and water supply to ensure that future development does not place a burden on existing customers. To provide new or increased water system infrastructure capacity needs due to new or intensified development. There are two primary components of this fee, the cost of system buy in and the cost of additional water supply assurance from the San Francisco Public Utilities Commission specifically for purpose of serving new development. The two components of the fee are accounted for and reported separately. The buy-in portion of the fee represents the cost of existing and future infrastructure related directly to new development. The supply portion of the fee represents the cost of water right assurances secured exclusively for serving new development. • East Palo Alto Sanitary District Sewer Impact Fees
To ensure new developments contribute to essential infrastructure upgrades, the East Palo Alto Sanitary District charges sewer impact fees based on the number of residential units and projected water usage. These fees are part of a broader development impact fee program that supports sewer and other infrastructure improvements.
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FY 2024-25 Fee Schedule
TABLE 1. AFFORDABLE HOUSING FEE
Non-Residential1
Commercial
$13.55

1. Fee Per Square Foot

TABLE 2. OTHER FEES
TABLE 3. STORM DRAINAGE FEE
Non-Residential1
Commercial
$13.55

1. Fee Per Square Foot
Fee Category
Detached
Accessory
Dwelling Unit
Single-Family/
Townhouse
Multi-family
Housing
Office /
Research &
Development
Industrial Retail
Parks and Trails $1,995 $4,987 $3,435 $1.40 $0.55 $0.92 Public Facilities $3,498 $8,746 $6,025 $2.42 $0.99 $1.61 Transportation Infrastructure $1,138 $2,845 $2,142 $8.84 $5.76 $8.84

1. Fee Per Dwelling Unit

2. Fee Per Square Foot
Residential1 Non-Residential2
19 9
TABLE 4. WATER CAPACITY FEE
TABLE 5. SANITARY DISTRICT SEWER SERVICE CHARGES
Fee Category
Detached
Accessory
Dwelling Unit
Single-Family /
Townhouse
Multi-family
Housing
Office /
Research &
Development
Industrial Retail
Storm Drainage (within RBD) $2,336 $5,840
Storm Drainage (outside RBD) $1,351 $3,379

1. Fee Per Dwelling Unit

2. Fee Per Impervious Acre
$84,467
$146,007
Single-Family1 Multi-Family and Non-Residential2
Single-Family /
Townhouse
Multi-family
Housing
3/4 Inch
Meter
1 inch
Meter

1.5 Inch
Meter
2 Inch
Meter Larger2
$9,831 $6,050 $14,368 $23,946 $47,894 $76,629 $37.80

1. Fee Per Dwelling Unit

2. Fee Per Anticipated Gallon Per Day
Residential Non-Residential 1
Residential1
Per Dwelling or
Living Unit
Restaurants
Educational
Facilities
Offices and
Churches
Motels/
Hotels Commercial Medical Insdustrial Recreational
$660 10.2042 5.5431 5.5431 6.3528 5.8826 6.3528 6.3528 5.8826

1. Fee Per Dwelling or Living Unit

2. Fee calculated based on each establishment's annual water consumption multiplied by the applicable rate Commercial and Industrial2
20 10
Fund Balances
Description Parks
and Trails
Public
Facilities Transportation
Storm
Drainage
Inside RBD
Revenue
Fees - $ - $ - $ - $
Interest - - - -
Total Revenue - $ - $ - $ - $
Expenditures - $ - $ - $ - $
Revenue Over (Under)
Expenditures $ - - $ - $ - $
Fund Balance
Beginning of Year 921,845 515,246 502,365 363,905
Fund Balance
End of Year $ 921,845 515,246 $ 502,365 $ 363,905 $
Description
Storm
Drainage
Outside RBD
Water - Buy In Water - Supply Sanitary
District Sewer
Revenue
Fees - $ 44,820 $ 2,458 $ - $
Interest - 40,990 - - $
Total Revenue - $ 85,810 $ 2,458 $ - $
Expenditures - $ $ 300,000 $ - $ -
Revenue Over (Under)
Expenditures $ (214,190) - $ 2,458 $ - $
Fund Balance
Beginning of Year 667,995 334,207 (4,820,513) -
Fund Balance
End of Year $ 453,805 334,207 $ (4,818,056) $ - $
21 11
Collection and Use
Parks and Trails Fees
Statement of Revenues, Expenditures and Changes in Fund Balance Last Five Fiscal Years
Five-Year Revenue Test Using First In First Out Method
Description FY20-21 FY21-22 FY22-23 FY23-24 FY24-25
Revenue
Fees 20,924 $ 8,779 $ 4,528 $ 465,095 $ 23,068 $
Interest 189 331 949 16,766 22,904
Total Revenue 21,113 $ 9,110 $ 5,476 $ 481,861 $ 45,972 $ Expenditures - $ - $ - $ 13,703 $ 4,862 $
Revenue Over (Under)
Expenditures $ 9,110 21,113 $ 5,476 $ 468,158 $ 41,110 $ Fund Balance Beginning of Year 11,389 32,502 41,612 47,089 515,246 Fund Balance End of Year 32,502 $ 41,612 $ 47,089 $ 515,246 $ 556,356 $ Revenue Available
After Expenses: FY20-21 FY21-22 FY22-23 FY23-24 FY24-25 Current Fiscal Year 21,113 $ 9,110 $ 5,476 $ 481,861 $ 45,972 $ Prior Fiscal Year (2-yr Old Funds) 11,389 21,113 9,110 5,476 481,861 Prior Fiscal Year (3-yr Old Funds) - 11,389 21,113 9,110 5,476 Prior Fiscal Year (4-yr Old Funds) - - 11,389 18,799 9,110 Prior Fiscal Year (5-yr Old Funds) - - - - 13,937
In Excess of Five Prior Fiscal Years - - - - -
Total Revenue Available 32,502 $ 41,612 $ 47,089 $ 515,246 $ 556,356 $ 22 12
Public Facilities Fees
Statement of Revenues, Expenditures and Changes in Fund Balance Last Five Fiscal Years
Five-Year Revenue Test Using First In First Out Method
Description FY20-21 FY21-22 FY22-23 FY23-24 FY24-25
Revenue
Fees 43,943 $ 15,396 $ 7,940 $ 815,671 $ 40,454 $
Interest 393 653 1,818 29,762 40,965
Total Revenue 44,336 $ 16,048 $ 9,758 $ 845,433 $ 81,420 $ Expenditures - $ - $ - $ 13,703 $ 4,862 $
Revenue Over (Under)
Expenditures $ 16,048 44,336 $ 9,758 $ 831,730 $ 76,558 $ Fund Balance Beginning of Year 19,973 64,309 80,357 90,116 921,845 Fund Balance End of Year 64,309 $ 80,357 $ 90,116 $ 921,845 $ 998,403 $ Revenue Available
After Expenses: FY20-21 FY21-22 FY22-23 FY23-24 FY24-25 Current Fiscal Year 44,336 $ 16,048 $ 9,758 $ 845,433 $ 81,420 $ Prior Fiscal Year (2-yr Old Funds) 19,973 44,336 16,048 9,758 845,433 Prior Fiscal Year (3-yr Old Funds) - 19,973 44,336 16,048 9,758 Prior Fiscal Year (4-yr Old Funds) - - 19,973 44,336 16,048 Prior Fiscal Year (5-yr Old Funds) - - - 6,270 44,336
In Excess of Five Prior Fiscal Years - - - - 1,408
Total Revenue Available 64,309 $ 80,357 $ 90,116 $ 921,845 $ 998,403 $ 23 13
Transportation Infrastructure Fees
Statement of Revenues, Expenditures and Changes in Fund Balance Last Five Fiscal Years
Five-Year Revenue Test Using First In First Out Method
Description FY20-21 FY21-22 FY22-23 FY23-24 FY24-25
Revenue
Fees 188,061 $ 5,103 $ 2,583 $ 288,780 $ 70,911 $
Interest 1,278 1,702 4,284 17,779 23,327
Total Revenue 189,339 $ 6,806 $ 6,867 $ 306,560 $ 94,238 $ Expenditures - $ - $ - $ 13,703 $ 4,862 $
Revenue Over (Under)
Expenditures $ 6,806 189,339 $ 6,867 $ 292,856 $ 89,375 $ Fund Balance Beginning of Year 6,498 195,836 202,642 209,509 502,365 Fund Balance End of Year 195,836 $ 202,642 $ 209,509 $ 502,365 $ 591,740 $ Revenue Available
After Expenses: FY20-21 FY21-22 FY22-23 FY23-24 FY24-25 Current Fiscal Year 189,339 $ 6,806 $ 6,867 $ 306,560 $ 94,238 $ Prior Fiscal Year (2-yr Old Funds) 6,498 189,339 6,806 6,867 306,560 Prior Fiscal Year (3-yr Old Funds) - 6,498 189,339 6,806 6,867 Prior Fiscal Year (4-yr Old Funds) - - 6,498 182,133 6,806 Prior Fiscal Year (5-yr Old Funds) - - - - 177,271
In Excess of Five Prior Fiscal Years - - - - -
Total Revenue Available 195,836 $ 202,642 $ 209,509 $ 502,365 $ 591,740 $ 24 14
Storm Drainage Inside RBD Fees
Statement of Revenues, Expenditures and Changes in Fund Balance Last Five Fiscal Years
Five-Year Revenue Test Using First In First Out Method
Description FY20-21 FY21-22 FY22-23 FY23-24 FY24-25
Revenue
Fees 185 $ 2,933 $ 1,880 $ 360,252 $ - $
Interest 6 30 111 11,828 15,873
Total Revenue 191 $ 2,963 $ 1,991 $ 372,080 $ 15,873 $
Expenditures - $ - $ - $ 13,703 $ 4,862 $
Revenue Over (Under)
Expenditures $ 2,963 191 $ 1,991 $ 358,377 $ 11,011 $
Fund Balance Beginning of Year 384 575 3,537 5,529 363,905 Fund Balance End of Year 575 $ 3,537 $ 5,529 $ 363,905 $ 374,917 $ Revenue Available
After Expenses: FY20-21 FY21-22 FY22-23 FY23-24 FY24-25 Current Fiscal Year 191 $ 2,963 $ 1,991 $ 363,905 $ 15,873 $ Prior Fiscal Year (2-yr Old Funds) 384 191 2,963 - 359,043 Prior Fiscal Year (3-yr Old Funds) - 384 191 - -
Prior Fiscal Year (4-yr Old Funds) - - 384 - -
Prior Fiscal Year (5-yr Old Funds) - - - - -
In Excess of Five Prior Fiscal Years - - - - -
Total Revenue Available 575 $ 3,537 $ 5,529 $ 363,905 $ 374,917 $ 25 15
Storm Drainage Outside RBD Fees
Statement of Revenues, Expenditures and Changes in Fund Balance Last Five Fiscal Years
Five-Year Revenue Test Using First In First Out Method
Description FY20-21 FY21-22 FY22-23 FY23-24 FY24-25
Revenue
Fees 259,678 $ 9,200 $ 6,085 $ 14,984 $ 27,849 $
Interest 1,954 2,454 6,236 12,912 15,039
Total Revenue 261,632 $ 11,655 $ 12,321 $ 27,895 $ 42,887 $ Expenditures - $ - $ - $ - $ - $
Revenue Over (Under)
Expenditures $ 11,655 261,632 $ 12,321 $ 27,895 $ 42,887 $ Fund Balance Beginning of Year 20,704 282,337 293,991 306,312 334,207 Fund Balance End of Year 282,337 $ 293,991 $ 306,312 $ 334,207 $ 377,094 $ Revenue Available
After Expenses: FY20-21 FY21-22 FY22-23 FY23-24 FY24-25 Current Fiscal Year 261,632 $ 11,655 $ 12,321 $ 27,895 $ 42,887 $ Prior Fiscal Year (2-yr Old Funds) 20,704 261,632 11,655 12,321 27,895 Prior Fiscal Year (3-yr Old Funds) - 20,704 261,632 11,655 12,321 Prior Fiscal Year (4-yr Old Funds) - - 20,704 261,632 11,655 Prior Fiscal Year (5-yr Old Funds) - - - 20,704 261,632 In Excess of Five Prior Fiscal Years - - - - 20,704
Total Revenue Available 282,337 $ 293,991 $ 306,312 $ 334,207 $ 377,094 $ 26 16
Water Capacity Fee – Buy In Component
Statement of Revenues, Expenditures and Changes in Fund Balance Last Five Fiscal Years
Description FY20-21 FY21-22 FY22-23 FY23-24 FY24-25
Revenue
Fees 390,680 $ 21,007 $ 13,590 $ 677,753 $ 44,820 $
Interest 444 498 9,024 21,822 40,990
Total Revenue 391,124 $ 21,505 $ 22,614 $ 699,575 $ 85,810 $ Expenditures - $ - $ 450,000 $ 13,703 $ 300,000 $
Revenue Over (Under)
Expenditures $ 21,505 391,124 $ (427,386) $ 685,872 $ (214,190) $ Fund Balance Beginning of Year (3, 388,004 120) 409,509 (17,877) 667,995 Fund Balance End of Year $ 409,509 388,004 $ (17,877) $ 667,995 $ 453,805 $ Five-Year Revenue Test Using First In First Out Method
Revenue Available
After Expenses: FY20-21 FY21-22 FY22-23 FY23-24 FY24-25 Current Fiscal Year 388,003 $ 21,505 $ - $ 667,995 $ 85,810 $ Prior Fiscal Year (2-yr Old Funds) - 388,003 - - 367,995 Prior Fiscal Year (3-yr Old Funds) - - - - -
Prior Fiscal Year (4-yr Old Funds) - - - - -
Prior Fiscal Year (5-yr Old Funds) - - - - -
In Excess of Five Prior Fiscal Years - - - - -
Total Revenue Available 388,003 $ 409,509 $ - $ 667,995 $ 453,804 $ 27 17
Water Capacity Fee – Supply Component
Statement of Revenues, Expenditures and Changes in Fund Balance Last Five Fiscal Years
Five-Year Revenue Test Using First In First Out Method
Description FY20-21 FY21-22 FY22-23 FY23-24 FY24-25
Revenue
Fees 82,019 $ 4,408 $ 8,040 $ 140,532 $ 2,458 $
Interest - - - - -
Total Revenue 82,019 $ 4,408 $ 8,040 $ 140,532 $ 2,458 $ Expenditures - $ - $ - $ - $ - $
Revenue Over (Under)
Expenditures $ 4,408 82,019 $ 8,040 $ 140,532 $ 2,458 $ Fund Balance Beginning of Year (5,055, (4,973,493) 512) (4,969,085) (4,961,046) (4,820,513) Fund Balance End of Year (4,973,493) $ (4,969,085) $ (4,961,046) $ (4,820,513) $ (4,818,056) $ Revenue Available
After Expenses: FY20-21 FY21-22 FY22-23 FY23-24 FY24-25 Current Fiscal Year - $ - $ - $ - $ - $
Prior Fiscal Year (2-yr Old Funds) - - - - -
Prior Fiscal Year (3-yr Old Funds) - - - - -
Prior Fiscal Year (4-yr Old Funds) - - - - -
Prior Fiscal Year (5-yr Old Funds) - - - - -
In Excess of Five Prior Fiscal Years - - - - -
Total Revenue Available - $ - $ - $ - $ - $
28 18
Affordable Housing Impact Fees
Statement of Revenues, Expenditures and Changes in Fund Balance No Affordable Housing fees subject to AB 1600 reporting requirements have been collected or expenses incurred through the period ended June 30, 2025.

29 19
East Palo Alto Sanitary District Sewer Impact Fees
Statement of Revenues, Expenditures and Changes in Fund Balance Description FY20-21 FY21-22 FY22-23 FY23-24 FY24-25
Revenue
Fees 606,469 $ 92,273 $ 1,621,222 $ 2,227,645 $ 64,698 $ Interest - - - - -
Total Revenue 606,469 $ 92,273 $ 1,621,222 $ 2,227,645 $ 64,698 $ Expenditures 591,622 $ 44,621 $ 1,572,401 $ 2,338,965 $ - $ Revenue Over (Under)
Expenditures $ 47,652 14,847 $ 48,821 $ (111,320) $ 64,698 $ Fund Balance Beginning of Year - 14,847 62,499 111,320 - Fund Balance End of Year 14,847 $ 62,499 $ 111,320 $ - $ 64,698 $ Five-Year Revenue Test Using First In First Out Method
Revenue Available
After Expenses: FY20-21 FY21-22 FY22-23 FY23-24 FY24-25 Current Fiscal Year 14,847 $ 62,499 $ 111,320 $ - $ 64,698 $ Prior Fiscal Year (2-yr Old Funds) - - - - -
Prior Fiscal Year (3-yr Old Funds) - - - - -
Prior Fiscal Year (4-yr Old Funds) - - - - -
Prior Fiscal Year (5-yr Old Funds) - - - - -
In Excess of Five Prior Fiscal Years - - - - -
Total Revenue Available 14,847 $ 62,499 $ 111,320 $ - $ 64,698 $ 30 Resolution No. XX-2025 1 of 2
RESOLUTION NO. XX– 2025

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO

ACCEPTING THE ANNUAL DEVELOPMENT IMPACT FEE REPORT FOR THE FISCAL YEAR 2024-25
WHEREAS, the City of East Palo Alto (“City”) levies development impact fees to finance the design, construction and acquisition for public infrastructure improvements, including facilities and equipment necessary to accommodate future growth and development within the City pursuant to Government Code section 66000 et. seq.; and
WHEREAS, said fees are collected and deposited into a special and separate fund for each type of development fee; and
WHEREAS, the City is required to make certain findings within 180 days following the last day of the fiscal year, each year, with respect to the unexpended fund balance of development impact fee funds pursuant to California Government Code Section 66001; and WHEREAS, the documents reflecting the balance in each development impact fee fund, the earnings collected from development impact fees, accrued interest in said fund, and the amount of expenditure from said fund have been made available to the public through the “AB 1600 Report.”; and WHEREAS, the AB 1600 Report was made available to the public for review on December 1, 2025, fifteen (15) days prior to the date that the City Council considered the AB 1600 Report.

NOW, THEREFORE, BE IT RESOLVED THAT THE CITY COUNCIL OF THE CITY OF EAST PALO ALTO HEREBY:

1. Finds the foregoing recitals are true and correct, and are incorporated by this reference into this action; and

2. Accepts the Annual Development Impact Fee Report for Fiscal Year 2024-25; and

3. Finds that the proposed action does not constitute a “project” with the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment.

PASSED AND ADOPTED this 16
th day of December 2025, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
31 Resolution No. XX-2025 2 of 2
Martha Barragan, Mayor
ATTEST: APPROVED AS TO FORM:

James Colin, City Clerk John D. Lê, City Attorney
32 CONSENT CALENDAR 3.1

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: December 16, 2025
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Amy Chen, Community and Economic Development Director Karen Camacho, Housing and Economic Development Manager Yajaira Morales, Housing Project Manager
SUBJECT: Agreement with Street Level Advisors and the Community Planning Collaborative in Updating the Inclusionary Housing Ordinance (IHO) and Guidelines Recommendation
Adopt a resolution:

1. Authorizing the City Manager to award, negotiate and execute a two-year agreement with Street Level Advisors in partnership with Community Planning Collaborative, in form approved by the City Attorney, in an amount not-to-exceed $75,000, and with two oneyear extensions at the sole discretion of the City Manager to provide project management and the updating of the Inclusionary Housing Ordinance (“IHO”) and guidelines; and

Executive Summary
Staff recommends awarding Street Level Advisors and Community Planning Collaborative through a joint contract to provide project management support in updating the Inclusionary Housing Ordinance (“IHO”) and guidelines. Currently the IHO is applicable to new residential developments in East Palo Alto and requires the development of affordable housing units.

Although the City Manager has the contract authority to award this Request for Proposals selection, City staff is providing this staff report and an overview of the scope of work for the IHO and guidelines update. If approved, staff will work with the City Attorney’s Office to prepare and 33 CONSENT CALENDAR 3.1
execute the agreement to begin implementation in early 2026. City staff and the selected respondents will return to City Council at an upcoming study session (tentatively scheduled for March) on the IHO to state what is in the current ordinance and solicit City Council direction for any research on inclusionary housing or amendments regarding the ordinance.

Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:
 Priority: Comprehensive Housing
Background
Affordable Housing Strategy and City Council Priorities On November 19, 20191, the City Council adopted Ordinance No. 425, the Inclusionary Housing Ordinance (“IHO”), adding Chapter 18.37 to the City of East Palo Alto Development Code. All residential development projects that create new dwelling units are subject to the IHO. During the past two years, the City has advanced several policy initiatives that support evaluating and refining the IHO, including the 2024–2028 Affordable Housing Strategy, the 2023–2031 Housing Element, the 2025–2029 City Council Strategic Priorities, and the Ravenswood/4 Corners Specific Plan Update. Each of these documents references components of the IHO—including its effectiveness, fee structure, and unit requirements—as a key City ordinance that supports affordable housing in East Palo Alto.

On October 21, 20252, City Council authorized execution of a Memorandum of Understanding (“MOU”) with Community Planning Collaborative (“CPC”) for participation in the 21 Elements Multi-Jurisdictional Grand Nexus and Feasibility Study (“Grand Nexus”). This study will analyze inclusionary housing feasibility, the relationship between commercial development and affordable housing needs, and commercial linkage fees. Preliminary inclusionary feasibility results are expected in late 2026 and could inform future amendments to the IHO. The Council also allocated $75,000 in FY 2025-26 to hire a third-party consultant to assist with an IHO policy analysis and amendment process.

The Inclusionary Housing Ordinance (IHO) and IHO Guidelines The City’s IHO has undergone various iterations over the years, starting in 1994 and culminating in its most recent form that was adopted in 2019. In its latest iteration, the City created Chapter

18.37 of the Development Code. Broadly speaking, the current IHO applies to all residential development, requiring either in-lieu fees or a 20% on-site inclusionary requirement. Alternative compliance options—including off-site units, accessory dwelling units (“ADUs”), land dedication, and in-lieu fee payments—are available with City Council approval.

1 November 19, 2019 City Council Meeting (item 9B):
https://eastpaloalto.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1211&Inline=True 2 October 21, 2025 City Council Meeting (item 12.2): https://d3n9y02raazwpg.cloudfront.net/cityofepa/221d99bdddd1-11ef-a9e2-005056a89546-3408cd31-ecd7-4429-9d91-65986d552499-1761095099.pdf 34 CONSENT CALENDAR 3.1
The 2019 ordinance also establishes affordability targets: for rental projects, inclusionary units must be distributed among Extremely Low-, Very Low-, and Low-Income households; for ownership projects, units must be split between Median- and Moderate-Income households.

More details on the IHO will be provided in the upcoming study session on this topic.

In 2020, David Paul Rosen & Associates prepared an Inclusionary Housing In-Lieu Fee Update study,3 and guidelines (“Guidelines”) were established and utilized in implementation. The Inclusionary Housing Guidelines provide detailed procedures for implementing the IHO, including eligibility, application, marketing, and compliance standards. They ensure consistent application across projects. Although specific chapters are updated annually to reflect revised rental and ownership in-lieu fee calculations, staff believe a review and evaluation of the Guidelines could also be beneficial at this time. These Guidelines will also be covered in more detail at the study session.

Updating the IHO and the Grand Nexus Study
The City is participating in the regional 21 Elements Grand Nexus Study, which will evaluate inclusionary housing feasibility, the relationship between commercial development and affordable housing needs, and commercial linkage fees. Strategic Economics is leading the study, with preliminary inclusionary feasibility results expected in late 2026. Strategic Economics is primarily scoped to focus on the data analysis and thus the selected project manager would focus on potential IHO amendments and coordinate with staff and Strategic Economics to present recommendations to the City Council.

Staff is therefore proposing to hire the selected consultant team to provide project oversight and analysis of the Grand Nexus Study results, review, evaluate, and recommend improvements to the City’s IHO and program guidelines, and conduct robust community and stakeholder outreach.

Analysis
The Request For Proposals, Review Process, and Staff’s Recommendation On October 1, 2025, the City issued a request for proposals (“RFP”) for qualified firms to conduct a comprehensive analysis of the City’s IHO and program guidelines. The RFP was due on October 27, 2025.

The City received three responses to the RFP released on October 1, 2025, from: 1) Grounded Solutions Network; 2) Street Level Advisors (SLA) and the Community Planning Collaborative (CPC) collectively; and 3) RSG Solutions. The proposals were reviewed by a three-member selection committee (Committee). Each Committee member independently scored the proposals following a review of the written submissions and interviews. All three respondents were interviewed on October 30, 2025, using the same set of questions. After careful evaluation, the

3 David Rosen & Associates In-Lieu Fee Study:
https://www.cityofepa.org/sites/default/files/fileattachments/housing/page/24965/chapter_2c_david_rosen_associa tes_inlieu_fee_study.pdf
35 CONSENT CALENDAR 3.1
Committee determined selected SLA and CPC as the most qualified proposers.

While all three proposers demonstrated relevant experience, RSG Solutions’ qualifications and approach did not align as closely with the City’s specific needs. Although Grounded Solutions Network presented a strong proposal and possesses the expertise, Grounded Solutions’ national focus presents a challenge in conducting the local community outreach. Therefore, the Committee concluded that SLA and CPC offer key advantages as a local team with a deep understanding of the East Palo Alto housing landscape.

SLA brings extensive experience in the development and management of inclusionary housing programs and other affordable housing policies across California jurisdictions. Their expertise in strategic housing policy implementation positions them well to guide the City through updates to the IHO. CPC complements this experience with strong technical capacity in housing economics, data analysis, and policy research. Importantly, CPC is leading the 21 Elements Grand Nexus and Feasibility Study that the City is participating in, which allows for seamless coordination between both efforts.

Under this partnership, SLA will serve as the lead consultant and primary point of contact, managing the IHO update process and providing analytical and technical support, while CPC will lead the community outreach and engagement work, breaking down information into a digestible form, and seamlessly connecting East Palo Alto’s work to the Grand Nexus. Together, they will ensure an efficient, well-informed, and community-centered approach to the project.

IHO Update
The objectives of the inclusionary housing update are to:
 Review the City’s current inclusionary housing ordinance, policies, and procedures.  Assess the effectiveness of existing inclusionary housing requirements in meeting affordable housing production, fair housing goals, Regional Housing Needs Allocation (RHNA) targets, and Housing Element goals.
 Identify barriers and opportunities for improving program outcomes, including legal, financial, and administrative considerations.
 Recommend policy, procedural, and operational improvements to enhance the City’s ability to meet its housing goals. This could include recommendations on:
o Development volume (number of total units) that triggers an inclusionary requirement.
o Percentage of total units that should be affordable at specific affordability levels.
o Variations in inclusionary requirements depending on progress toward RHNA targets.
 Engage stakeholders, including elected officials, developers, affordable housing advocates, and the broader community, to inform the analysis and recommendations. 36 CONSENT CALENDAR 3.1
Next Steps
If the City Council authorizes the approval of the agreement with the selected firm, staff will work with the City Attorney’s Office to prepare and execute the agreement to be operational in early 2026.

Staff and the contractor are aiming to return to City Council by March 24, 2026, for a Study Session on the IHO, kicking off the IHO update and the Grand Nexus Study.

Fiscal Impact
The proposed agreement is not-to-exceed $75,000. This amount is already budgeted from the Housing In Lieu Fund in the FY 2025-26 budget, so no new appropriation is necessary.

Public Notice
The public was provided notice by making the agenda and report available on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto.

Government Code § 84308
Applicability of Levine Act: No, the proposed action involves a competitively bid contract.

Analysis of Levine Act Compliance: Not applicable.

Attachments

1. Resolution
37 Resolution No. XX-2025 1 of 2
RESOLUTION NO. XX– 2025

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO

AUTHORIZING THE CITY MANAGER TO EXECUTE AN AGREEMENT WITH STREET

LEVEL ADVISORS IN UPDATING THE INCLUSIONARY HOUSING ORDINANCE (IHO)

AND GUIDELINES
WHEREAS, on November 19, 2019, the City Council of the City of East Palo Alto (“City Council”) adopted Ordinance No. 425 (“IHO”), adding Chapter 18.37 – Inclusionary Housing to the City of East Palo Alto Municipal Code; and
WHEREAS, on October 21, 2025, the City Council authorized execution of a Memorandum of Understanding (“MOU”) with Community Planning Collaborative (“CPC”) and Strategic Economics and for the City to participate in the 21 Elements Multi-Jurisdictional Grand Nexus and Feasibility Study (“Grand Nexus”); and
WHEREAS, on that same date, the Council also allocated $75,000 in FY 2025-26 to hire a thirdparty consultant to assist with this policy analysis and update process; and WHEREAS, the City released a request for proposals (RFP) on October 1, 2025, seeking qualified consultants to conduct a comprehensive review and update of the Inclusionary Housing Ordinance and guidelines; and
WHEREAS, the City of East Palo Alto received three proposals in response to the RFP by the October 27, 2025 deadline and staff interviewed all respondents on October 30, 2025; and WHEREAS, after careful review, City staff recommend contracting with Street Level Advisors, in partnership with the Community Planning Collaborative (CPC), to provide project oversight and analysis of the Grand Nexus Study results, review, evaluate, and recommend improvements to the City’s IHO and program guidelines, and conduct robust community and stakeholder outreach.

NOW, THEREFORE, BE IT RESOLVED THAT THE CITY COUNCIL OF THE CITY OF EAST PALO ALTO HEREBY:

1. Finds the foregoing recitals are true and correct, and are incorporated by this reference into this action;

2. Authorizes the City Manager to award, negotiate and execute a two-year agreement with Street Level Advisors in partnership with Community Planning Collaborative, in form approved by the City Attorney, in an amount not-to-exceed $75,000, and with two one-year extensions at the sole discretion of the City Manager to provide project management and the updating of the Inclusionary Housing Ordinance (“IHO”) and guidelines; and

AYES:

NOES:

ABSENT:

ABSTAIN:
_______________, Mayor
ATTEST: APPROVED AS TO FORM:

James Colin, City Clerk John D. Lê, City Attorney
39 CONSENT ITEM 3.4

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: December 16, 2025
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: James Colin, City Clerk
SUBJECT: City Council Meeting Minutes
Recommendation
Adopt December 2, 2025, minutes.

Attachments

1. December 2, 2025, Minutes
40 EAST PALO ALTO CITY COUNCIL

REGULAR SESSION MINUTES
Tuesday, December 2, 2025, 6:30 PM
EPA Government Center
2415 University Avenue, First Floor
East Palo Alto, CA 94303

1. CALL TO ORDER AND ROLL CALL
The City Council meeting was called to order by Mayor Barragan at 6:31 PM.

Attendee Name Title Status Arrived
Martha Barragan Mayor Present
Mark Dinan Vice Mayor Present
Carlos Romero Councilmember Present
Ruben Abrica Councilmember Present
Webster Lincoln Councilmember Present

2. APPROVAL OF THE AGENDA
A motion to approve the agenda was made by Councilmember Lincoln, seconded by Vice Mayor Dinan, and passed unanimously.

3. APPROVAL OF CONSENT CALENDAR
Councilmember Romero pulled item 3.3 for discussion.

A motion to approve the consent calendar was made by Councilmember Romero, seconded by Councilmember Lincoln, and passed unanimously.

3.1 East Palo Alto 2025 Cross Connection Control Plan

3.2 Authorize the award and execution of multiple contracts for Human Resources Support Services with a five-year contract with a possible oneyear extension at the City Manager’s discretion for services with a shared not-to-exceed (NTE) amount of $400,000

3.3 City Council’s Proposed Schedule for 2026
Councilmember Romero and Vice Mayor Dinan posed questions regarding the 2026 Council meeting schedule. The schedule was updated to reflect a change to remove the study session meeting on December 8 and replace it with the Council reorganization meeting and to move the study session in June from June 30 to June 23.

A motion to approve item 3.3 was made by Councilmember Romero, seconded by Vice Mayor Dinan, and passed unanimously.

3.4 City Council Meeting Minutes
41 3.5 Proclamation of the City of East Palo Alto honoring Officer Paul Norris for 38 years of exemplary service to the City of East Palo Alto.

4. CLOSED SESSION

5. PUBLIC COMMENT
The following speakers provided public comments:
- Alex Young
- Jazon Auzenne
- Dakota Jenkins (via recorded video)
- Michael Mashack
- Laura Rubio
- Ravneel
- Marianna Sumina
- Gail Xizon
- Veronica Cazzalli

6. ADJOURN CITY COUNCIL REGULAR MEETING TO THE EAST PALO

ALTO SANITARY DISTRICT BOARD MEETING

7. APPROVAL OF EPASD BOARD MEETING CONSENT CALENDAR
A motion to approve the EPASD consent calendar was made by Councilmember Romero, seconded by Mayor Barragan, and passed unanimously.

7.1 Award Agreements to Two Consulting Firms for Engineering On-Call Services

7.2 Cash Disbursement Report for October 2025

8. ADJOURN EAST PALO ALTO SANITARY DISTRICT BOARD MEETING

AND RECONVENE CITY COUNCIL REGULAR MEETING

9. INFORMATIONAL REPORTS

9.1 2025 Summer Park Activation Results
Maurice Baker, Community Services Manager, and Vincent Amelio Recreation Program Coordinator, provided a presentation and answered questions posed by the City Council.

The following speakers provided public comments:
- Ofelia Bello
- Gail Dixon

9.2 Street Sweeping Signage Audit Project Presentation
Humza Javed, Public Works Director, and Diana Tran, Environmental Services Aide, provided a presentation and answered questions posed by the City Council. - The following speakers provided public comments:
- Gail Dixon
- Mario Pulido
42 - Luis Rosas

10. SPECIAL PRESENTATIONS

11. PUBLIC HEARINGS

11.1 Introduction of Chapter 5.76 – Sidewalk Vendors Ordinance Denise Garcia, Assistant to the City Manager, provided a presentation on item 11.1 and answered questions posed by the City Council.

The following:
- Kenia N.
- Gail Dixon
- Francisca Guzman
- Mario
- Laura Rubio
- Ravneel
- Fili
A motion to approve item 11.1 was made by Councilmember Lincon, seconded by Vice Mayor Dinan, and did not pass.

A motion to continue item 11.1 was made by Councilmember Abrica, seconded Councilmember Romero, and did not pass.

This item was continue to a future council meeting by default.

12. POLICY AND ACTION

12.1 Continued use of Automated License Plate Recognition Systems for Enhanced Public Safety
Jeff Liu, Chief of Police, and Lily Ho from Flock Safety, provided a presentation on item

12.1 and answered questions posed by the City Council.

The following speakers provided public comments:
- Luis Rosas
- Laura Rubio
- Francisca Guzman
- Kenia Najar
- Raneel
- Fili
- Danae Moreno
- David Watson
- Gail Dixon
- Mario
- Dylan
- Estefani Ruiz
- Janelle
- Moana
- Lavain Henderson
- Austin M.
- Xenia Hernandez
43 - Linda Baker
- Marianna Sumina
- Palo Mobile Estates
A motion to approve item 12.1 with the amendment that the contract would be for 3 years was made by Mayor Barragan and seconded by Vice Mayor Dinan and passed with the following votes:

Councilmember Abrica: Nay
Councilmember Lincoln: Aye
Mayor Barragan: Aye
Vice Mayor Dinan: Aye
Councilmember Romero: Nay

13. COUNCIL REPORTS

14. ADJOURNMENT
The meeting was adjourned at 11:22 PM
44 POLICY & ACTION 9.1

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: December 16, 2025
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: James Colin, City Clerk
SUBJECT: Resolution Modifying Regular City Council Meeting Start Times to 5:30 pm Recommendation
Consider adopting a resolution establishing regular City Council meetings on the first and third Tuesdays of each month with a one hour earlier start time of 5:30 pm.

Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:
 Priority: Governance, Organizational Strength, and Fiscal Sustainability Background
East Palo Alto Municipal Code Section 2.08.010 authorizes the City Council to set the date and time of City Council meetings by resolution. The most recent resolution that establishes this schedule is Resolution No. 5061 (Attachment 2), adopted on December 18, 2018. Resolution 5061 sets regular City Council meetings for the first and third Tuesdays of each month beginning at 6:30 p.m.

Since 2018, the City Council has approved an annual meeting calendar by motion that follows the schedule established in Resolution 5061. Most recently, on December 2, 2025, the City Council approved the 2026 meeting calendar (Attachment 3), which retains regular meetings on the first and third Tuesdays at 6:30 p.m. and includes additional special meetings and study sessions with varying start times.

During the discussion of the 2026 calendar, council members expressed interest in starting 45 POLICY & ACTION 9.1
regular City Council meetings one hour earlier, at 5:30 p.m. The Council directed staff to prepare a resolution for Council consideration that would change the regular meeting start time from 6:30 p.m. to 5:30 p.m.

Analysis
The City Council has modified its regular meeting schedule several times over the years:
 Resolution 5 set regular meetings on the first and third Mondays at 8:00 p.m.  Resolution 127 retained the same Mondays but changed start times to 6:45 p.m. for workshops and 7:30 p.m. for regular meetings.
 Resolution 1861 (2001) moved regular meetings to the first and third Tuesdays at 7:30 p.m.
 Resolution 5061 (2018) maintained Tuesday meetings but moved the start time to 6:30 p.m.

Beyond requiring that the Council set meeting dates and times by resolution, Municipal Code Section 2.08.010 does not impose additional requirements. Both Resolution 1861 and Resolution 5061 included findings that modifying meeting dates and times served the public interest. Consistent with this precedent, the City Council may consider whether moving the regular meeting start time to 5:30 p.m. is in the public interest. 2026 City Council Meeting Dates
On December 2, 2025, the City Council approved the 2026 meeting calendar. The calendar includes 20 regular meetings, 5 study sessions, 2 special budget meetings, and 4 special meetings, including the Saturday, February 7, 2026, City Council team-building retreat and the Tuesday, December 8, 2026, City Council Reorganization meeting. The Council may schedule additional study sessions or special meetings as needed.

Regular Meetings
The approved 2026 calendar sets all regular meetings on the first and third Tuesdays, except for the following adjustments:
 August (4th and 18th): Canceled for the Council’s traditional August recess.  Holiday and Cultural Observance Adjustments:
o The February 17 meeting was rescheduled to Tuesday, February 24 to avoid conflict with Chinese New Year.
o The second May budget study session was scheduled for Thursday, May 21 to avoid conflict with Eid Al-Adha.
o The November 3 meeting was rescheduled to Tuesday, November 10 due to the November 3 election.
46 POLICY & ACTION 9.1
If the City Council adopts the draft resolution, all regular meetings in 2026, and these adjusted dates, would begin at 5:30 p.m.

Special Study Sessions
Special Study Sessions provide the Council dedicated time to discuss major topics such as development, infrastructure, and City finances. The 2026 calendar includes the following study sessions:
 Tuesday, March 24 at 6:00 p.m.
 Tuesday, June 9 at 6:00 p.m.
 Tuesday, June 30 at 6:00 p.m.
 Tuesday, July 28 at 6:00 p.m.
 Tuesday, September 29 at 6:00 p.m.

If the City Council adopts the draft resolution, these sessions would begin at 5:30 p.m.

Special Budget Meetings
Special budget meetings ensure the Council has sufficient time to review and adopt the City’s budget before the June 30, 2026 deadline. The 2026 budget meetings are scheduled for:
 Tuesday, May 12 at 6:00 p.m.
 Thursday, May 21 at 6:00 p.m. (if needed)
If the City Council adopts the draft resolution, both budget meetings would start at 5:30 p.m.

City Council Team Building
The Council scheduled a team-building session for Saturday, February 7, 2026, from 9:00 a.m. to 1:00 p.m. This meeting would remain scheduled for a 9:00 a.m. start time unless the Council chooses to change it in the future.

Public Notice
The public was provided notice of this agenda item by posting the City Council agenda on the City’s official bulletin board outside City Hall and making the agenda and report available at the City’s website and at the San Mateo County Library located at 2415 University Avenue, East Palo Alto.

Environmental
The proposed action does not constitute a “project” with the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment. 47 POLICY & ACTION 9.1
Attachments

1. Resolution

2. Resolution No. 5061

3. Approved 2026 City Council Calendar

4. Proposed 2025 Calendar with 5:30 pm start times.
48 Resolution No. XX-2025 1 of 2
RESOLUTION NO. XX– 2025

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO

ESTABLISHING REGULAR CITY COUNCIL MEETINGS ON THE FIRST AND THIRD TUESDAYS OF EACH MONTH AT 5:30 PM
WHEREAS, East Palo Alto Municipal Code Section 2.08.010 authorizes the City Council to set the date and time of regular City Council meetings by resolution; and WHEREAS, the City Council last established regular meeting dates and times through Resolution No. 5061, adopted on December 18, 2018, which set regular meetings on the first and third Tuesdays of each month beginning at 6:30 p.m.; and
WHEREAS, each subsequent year, the City Council has adopted annual meeting calendars consistent with Resolution No. 5061, including the 2026 meeting calendar approved on December 2, 2025; and
WHEREAS, during its discussion of the 2026 meeting calendar, the City Council expressed interest in starting regular City Council meetings one hour earlier, at 5:30 p.m., to support greater public participation, improve meeting efficiency, and accommodate community and councilmember schedules; and
WHEREAS, the City Council directed staff to prepare a resolution modifying the start time of regular City Council meetings for Council consideration; and WHEREAS, the City Council finds that establishing a 5:30 p.m. start time for regular City Council meetings on the first and third Tuesdays of each month serves the public interest and promotes effective governance.

NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of East Palo Alto hereby establishes the regular City Council meetings on the first and third Tuesdays of each month beginning at 5:30 p.m.

BE IT FURTHER RESOLVED that this resolution supersedes any conflicting provisions in prior resolutions, including Resolution No. 5061, relating to the start time of regular City Council meetings.

BE IT FURTHER RESOLVED that special meetings, study sessions, and other duly scheduled meetings may continue to be held at dates and times set by the City Council in accordance with the Ralph M. Brown Act and the East Palo Alto Municipal Code. 49 Resolution No. XX-2025 2 of 2
PASSED AND ADOPTED this 16
th day of December 2025, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
_______________, Mayor
ATTEST: APPROVED AS TO FORM:

James Colin, City Clerk John D. Lê, City Attorney
50 RESOLUTION NO. 5061

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF EAST PALO ALTO ESTABLISHING A NEW START TIME OF 6:30 PM FOR REGULAR

CITY COUNCIL MEETINGS
WHEREAS, in 2001, the City Council adopted Resolution No. 1860 establishing that regular City Council meeting take place on the first and third Tuesdays ofthe month and commence at 6:30 pm; and
WHEREAS, at the December 4, 2018 City Council meeting, the Council directed City staff to bring forth a resolution changing the regular City Council meeting start time to 6:30 pm on the first and third Tuesdays of every month except for Council recess; and WHEREAS, the City Council hereby finds and determines that it is in the public interest to establish an earlier start time for regular City Council meetings.

NOW, THEREFORE, BE IT RESOLVED THAT THE CITY COUNCIL OF THE CITY OF EAST PALO ALTO' HEREBY:

1. Affirms that regular City Council meetings take place on the first and third Tuesdays of the month;

2. Establishes a new start time of 6:30 pm for regular City Council meetings;

3. Determines that the new City Council start time shall take effect on January 15,2019; and

4. Rescinds Resolution No. 1860.

PASSED AND ADOPTED this 18th day of December 2018, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

ATTEST:

WALLACE- JONES, MOODY, GAUTHIER, ROMERO
NONE
ABRICA
NONE
51 Su Mo Tu We Th Fr Sa JAN Su Mo Tu We Th Fr Sa APR
1 2 3 6 - Regular Meeting @ 6:30 pm 1 2 3 4 7 - Regular Meeting @ 6:30 pm 4 5 6 7 8 9 10 20 - Regular Meeting @ 6:30 pm 5 6 7 8 9 10 11 21 - Regular Meeting @ 6:30 pm 11 12 13 14 15 16 17 12 13 14 15 16 17 18
18 19 20 21 22 23 24 19 20 21 22 23 24 25
25 26 27 28 30 31 26 27 28 29 30
Su Mo Tu We Th Fr Sa FEB Su Mo Tu We Th Fr Sa MAY
1 2 3 4 5 6 7 3 - Regular Meeting @ 6:30 pm 1 2 5 - Regular Meeting @ 6:30 pm 8 9 10 11 12 13 14 7 - Team Building Retreat @ 9:00 am 3 4 5 6 7 8 9 12 - Budget Meeting @ 6:00 pm 15 16 17 18 19 20 21 24 - Special Meeting @ 6:30 pm 10 11 12 13 14 15 16 19 - Regular Meeting @ 6:30 pm 22 23 24 25 26 27 28 17 18 19 20 21 22 23 21 - Budget Meeting @ 6:00 pm 24 25 26 27 28 29 30
31 Su Mo Tu We Th Fr Sa MAR Su Mo Tu We Th Fr Sa JUN
1 2 3 4 5 6 7 3 - Regular Meeting @ 6:30 pm 1 2 3 4 5 6 2 - Regular Meeting @ 6:30 pm 8 9 10 11 12 13 14 17 - Regular Meeting @ 6:30 pm 7 8 9 10 11 12 13 9 - Study Session @ 6:00 pm 15 16 17 18 19 20 21 24 - Study Session @ 6:00 pm 14 15 16 17 18 19 20 16 - Regular Meeting @ 6:30 pm 22 23 24 25 26 27 28 21 22 23 24 25 26 27 23 - Study Session @ 6:00 pm 29 30 31 28 29 30
2026 CITY COUNCIL MEETING

SCHEDULE
52 Su Mo Tu We Th Fr Sa JUL Su Mo Tu We Th Fr Sa OCT
1 2 3 4 7 - Regular Meeting @ 6:30 pm 1 2 3
5 6 7 8 9 10 11 21 - Regular Meeting @ 6:30 pm 4 5 6 7 8 9 10 12 13 14 15 16 17 18 28 - Study Session @ 6:00 pm 11 12 13 14 15 16 17 19 20 21 22 23 24 25 18 19 20 21 22 23 24
26 27 28 29 30 31 25 26 27 28 29 30 31
Su Mo Tu We Th Fr Sa AUG Su Mo Tu We Th Fr Sa NOV
1 1 2 3 4 5 6 7 10 - Special Meeting @ 6:30 pm
2 3 4 5 6 7 8 8 9 10 11 12 13 14
9 10 11 12 13 14 15 15 16 17 18 19 20 21
16 17 18 19 20 21 22 22 23 24 25 26 27 28
23 24 25 26 27 28 29 29 30
30 31
Su Mo Tu We Th Fr Sa SEP Su Mo Tu We Th Fr Sa DEC
1 2 3 4 5 1 2 3 4 5 1 - Regular Meeting @ 6:30 pm
6 7 8 9 10 11 12 6 7 8 9 10 11 12 8 - Reorg Meeting @ 6:00 pm 13 14 15 16 17 18 19 13 14 15 16 17 18 19 15 - Regular Meeting @ 6:30 pm 20 21 22 23 24 25 26 20 21 22 23 24 25 26
27 28 29 30 27 28 29 30 31
4 - Cancelled Meeting (Council Recess)
17 - Regular Meeting @ 6:30 pm
1 - Regular Meeting @ 6:30 pm
15 - Regular Meeting @ 6:30 pm
29 - Study Session @ 6:00 pm
18 - Cancelled Meeting (Council Recess)

CITY COUNCIL MEETING

SCHEDULE
6 - Regular Meeting @ 6:30 pm
20 - Regular Meeting @ 6:30 pm
2026
53 Su Mo Tu We Th Fr Sa JAN Su Mo Tu We Th Fr Sa APR
1 2 3 6 - Regular Meeting @5:30 pm 1 2 3 4 7 - Regular Meeting @ 5:30 pm 4 5 6 7 8 9 10 20 - Regular Meeting @ 5:30 pm 5 6 7 8 9 10 11 21 - Regular Meeting @5:30 pm 11 12 13 14 15 16 17 12 13 14 15 16 17 18
18 19 20 21 22 23 24 19 20 21 22 23 24 25
25 26 27 28 30 31 26 27 28 29 30
Su Mo Tu We Th Fr Sa FEB Su Mo Tu We Th Fr Sa MAY
1 2 3 4 5 6 7 3 - Regular Meeting @5:30 pm 1 2 5 - Regular Meeting @ 5:30 pm 8 9 10 11 12 13 14 7 - Team Building Retreat @ 9:00 am 3 4 5 6 7 8 9 12 - Budget Meeting @ 5:30 pm 15 16 17 18 19 20 21 24 - Special Meeting @ 5:30 pm 10 11 12 13 14 15 16 19 - Regular Meeting @ 5:30 pm 22 23 24 25 26 27 28 17 18 19 20 21 22 23 21 - Budget Meeting @ 5:30 pm 24 25 26 27 28 29 30
31 Su Mo Tu We Th Fr Sa MAR Su Mo Tu We Th Fr Sa JUN
1 2 3 4 5 6 7 3 - Regular Meeting @ 5:30 pm 1 2 3 4 5 6 2 - Regular Meeting @ 5:30 pm 8 9 10 11 12 13 14 17 - Regular Meeting @ 5:30 pm 7 8 9 10 11 12 13 9 - Study Session @ 5:30 pm 15 16 17 18 19 20 21 24 - Study Session @5:30 pm 14 15 16 17 18 19 20 16 - Regular Meeting @ 5:30 pm 22 23 24 25 26 27 28 21 22 23 24 25 26 27 30 - Study Session @ 5:30 pm 29 30 31 28 29 30
2026 CITY COUNCIL MEETING

SCHEDULE
54 Su Mo Tu We Th Fr Sa JUL Su Mo Tu We Th Fr Sa OCT
1 2 3 4 7 - Regular Meeting @ 5:30 pm 1 2 3
5 6 7 8 9 10 11 21 - Regular Meeting @ 5:30 pm 4 5 6 7 8 9 10 12 13 14 15 16 17 18 28 - Study Session @ 5:30 pm 11 12 13 14 15 16 17 19 20 21 22 23 24 25 18 19 20 21 22 23 24
26 27 28 29 30 31 25 26 27 28 29 30 31
Su Mo Tu We Th Fr Sa AUG Su Mo Tu We Th Fr Sa NOV
1 1 2 3 4 5 6 7 10 - Special Meeting @ 5:30 pm
2 3 4 5 6 7 8 8 9 10 11 12 13 14
9 10 11 12 13 14 15 15 16 17 18 19 20 21
16 17 18 19 20 21 22 22 23 24 25 26 27 28
23 24 25 26 27 28 29 29 30
30 31
Su Mo Tu We Th Fr Sa SEP Su Mo Tu We Th Fr Sa DEC
1 2 3 4 5 1 2 3 4 5 1 - Regular Meeting @ 5:30 pm
6 7 8 9 10 11 12 6 7 8 9 10 11 12 8 - Reorg Meeting @ 5:30 pm 13 14 15 16 17 18 19 13 14 15 16 17 18 19 15 - Regular Meeting @ 5:30 pm 20 21 22 23 24 25 26 20 21 22 23 24 25 26
27 28 29 30 27 28 29 30 31
4 - Cancelled Meeting (Council Recess)
17 - Regular Meeting @ 5:30 pm
1 - Regular Meeting @ 5:30 pm
15 - Regular Meeting @ 5:30 pm
29 - Study Session @ 5:30 pm
18 - Cancelled Meeting (Council Recess)

CITY COUNCIL MEETING

SCHEDULE
6 - Regular Meeting @ 5:30 pm
20 - Regular Meeting @ 5:30 pm
2026
55 POLICY AND ACTIONS 9.2

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: December 16, 2025
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Tomohito Oku, Finance Director
SUBJECT: Internal Control Policy
Recommendation
Adopt a resolution:

1. Approving the City of East Palo Alto Internal Control Policy;

2. Accepting implementation framework in response to the 2023-24 San Mateo County Civil Grand Jury Report “Assessing and Reporting Internal Controls”;

3. Receiving Internal Control Procedures Manual and Example Risk Register; and

4. Finding that the proposed action does not constitute a “project” with the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment.

Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:

Priority: Civic Engagement
Priority: Comprehensive Housing
Priority: Governance, Organizational Strength, and Fiscal Sustainability Priority: Land Use, Economic and Workforce Development
Priority: Parks, Recreation, and Community Facilities
Priority: Public Health, Safety, and Quality of Life
Priority: Public Infrastructure and Utilities
56 POLICY AND ACTIONS 9.2
Background
On June 27, 2024, the San Mateo County Civil Grand Jury issued a report titled “Assessing and Reporting Internal Controls in San Mateo County Agencies and School Districts.” The Grand Jury found that most agencies do not formally assess internal controls or report assessment results to their governing boards. The report issued three key recommendations (R1–R3) requiring all entities—including the City of East Palo Alto—to:
 R1: Document organizational risks and address those risks in an annual internal control assessment;
 R2: Complete an annual management assessment of internal controls; and  R3: Report the results of the assessment to the governing board and the public.

The City submitted its official response to the Grand Jury on September 17, 2024, agreeing in part with the findings and committing to implement a structured internal control framework consistent with the U.S. GAO “Green Book” and the California State Controller’s Internal Control Guidelines for Local Agencies.

Analysis
Overview of Internal Controls and Framework
Internal controls are the policies, procedures, and activities designed to provide reasonable assurance that an organization will achieve its objectives in the areas of operations, reporting, and compliance. They serve as safeguards to protect public assets, promote accurate financial reporting, ensure compliance with laws and regulations, and prevent or detect fraud, waste, and abuse.

The City’s internal control framework follows the U.S. Government Accountability Office’s Green Book, which is based on the Committee of Sponsoring Organizations of the Treadway Commission (COSO) model. The COSO framework—also cited in the San Mateo County Civil Grand Jury’s findings and recommendations—provides the professional standard for designing, implementing, and evaluating internal control systems across public and private organizations.

The COSO/Green Book framework defines five interrelated components that together form the foundation of an effective internal control system:

1. Control Environment – The organizational culture that sets the tone for integrity, ethical values, and accountability.

2. Risk Assessment – The process of identifying and analyzing risks that could prevent the City from achieving its objectives.

3. Control Activities – The specific actions and procedures established to mitigate identified risks.

4. Information and Communication – The means by which relevant information is 57 POLICY AND ACTIONS 9.2
captured, shared, and used to support internal control responsibilities.

5. Monitoring – Ongoing or periodic evaluations that ensure controls remain effective and deficiencies are addressed.

These components provide a comprehensive and adaptable framework for integrating internal controls into all levels of City operations—from financial management and budgeting to technology, compliance, and service delivery.

Internal control systems are designed to provide reasonable assurance, recognizing that absolute assurance is neither feasible nor cost-effective. The cost of implementing and maintaining internal controls should not exceed the benefits derived from those controls.

Accordingly, the City’s approach emphasizes risk-based prioritization, allocating resources where controls provide the greatest value in reducing the likelihood or impact of errors, inefficiencies, or noncompliance.

Internal Control Policy and Implementation Framework
To comply with the Grand Jury’s recommendations and ensure practical, sustainable management of internal controls, staff proposes a framework that clearly distinguishes between Council oversight and management implementation responsibilities.  Internal Control Policy (Governance Framework):

Establishes the overarching requirements, expectations, and accountability structure for internal controls. The policy sets the tone for organizational integrity, defines Council’s oversight role, and formalizes management’s responsibility for maintaining an effective internal control environment.

The policy is a Council-approved document that represents the City’s official commitment to sound internal control practices and may be amended only through Council action.

Please see the Attachment 2: City of East Palo Alto Internal Control Policy.  Internal Control Procedures Manual (Operational Tools):

Provides detailed instructions, templates, and working documents necessary to implement the policy. The manual guides staff through documenting risks, conducting assessments, maintaining the Risk Register, and preparing reports to Council.

Because the manual describes administrative procedures, it is a management document that may be updated periodically by the City Manager or Finance Director to reflect organizational changes, new systems, or best practices—without requiring separate Council approval.

Please see the Attachment 3: Internal Control Procedures Manual and the Attachment 4:

Example Citywide Risk Register.

This governance and management framework ensures clear accountability: the policy defines 58 POLICY AND ACTIONS 9.2
what must be achieved and who is responsible, while the manual defines how those requirements are implemented and maintained. This separation allows the Council to focus on oversight and policy direction, while management retains flexibility to refine implementation tools and respond to evolving operational needs.

Policy Overview (Attachment 2)
The proposed Internal Control Policy affirms the City’s commitment to:
 A comprehensive control environment based on the Green Book’s five components and seventeen principles;
 Periodic documentation of citywide risks;
 Annual assessment and continuous improvement; and
 Transparent reporting to Council and the community.

Procedures Manual and Example Risk Register (Attachment 3 and 4) The accompanying Procedures Manual details how departments will:
 Identify, rate, and document risks;
 Evaluate the design and effectiveness of related controls;  Develop and track corrective action plans; and
 Maintain a Citywide Risk Register linked to Green Book principles across major City operations, including:
o Finance: accounts payable and disbursements, payroll, treasury, cash receipting, budgeting, financial reporting, and grant compliance;
o Information Technology: system user-rights management, cybersecurity controls, password and multi-factor authentication practices, and disaster-recovery readiness.

Future Reporting
The Internal Control Policy establishes ongoing reporting requirements to ensure transparency, accountability, and continuous improvement.

In accordance with the Monitoring component of the COSO/Green Book framework, management will evaluate the effectiveness of internal controls on a recurring basis and communicate the results to the City Council through formal reporting. These reports will summarize the results of risk assessments, key control activities, and corrective actions implemented, providing the Council with a structured overview of the City’s internal control environment and progress over time.

Grand Jury Recommendations
Implementation of the Internal Control Policy and Procedures Manual directly fulfills the 59 POLICY AND ACTIONS 9.2
requirements outlined in the 2023–24 San Mateo County Civil Grand Jury report “Assessing and Reporting Internal Controls”:
 R1 – Document Organizational Risks:

Addressed through the creation and maintenance of a citywide Risk Register, supported by detailed departmental documentation processes outlined in the Procedures Manual.  R2 – Conduct an Annual Assessment of Internal Controls:

Addressed through the internal assessment and evaluation framework detailed in the Policy and Manual, which establishes systematic review and validation of internal control effectiveness.
 R3 – Report the Assessment Results to the Governing Body and Public:

Addressed through the Annual Internal Control Report, prepared by management in accordance with the Policy’s reporting requirements and aligned with the Monitoring and Information & Communication components of the COSO/Green Book framework.

Together, these measures complete the City’s response to the Grand Jury’s recommendations and institutionalize a sustainable process for documenting, assessing, and reporting internal controls.

Fiscal Impact
Implementation will occur within existing staff resources. Any specialized training or system improvements identified through the annual assessment will be incorporated into future budget proposals.

Public Notice
The public was provided notice by making the agenda and report available on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto.

Government Code § 84308
Applicability of Levine Act: No, as the proposed action does not involve an entitlement.

Analysis of Levine Act Compliance: Not applicable.

Attachments
60 POLICY AND ACTIONS 9.2

1. Resolution.

2. City’s Internal Control Policy

3. Internal Control Procedure Manual

4. Example Risk Register
61 Resolution No. XX-2025 1 of 2
RESOLUTION NO. XX– 2025

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO

ADOPT A RESOLUTION APPROVING THE CITY OF EAST PALO ALTO INTERNAL CONTROL POLICY; ACCEPTING THE IMPLEMENTATION FRAMEWORK IN RESPONSE TO THE 2023–24 SAN MATEO COUNTY CIVIL GRAND JURY REPORT “ASSESSING AND REPORTING INTERNAL CONTROLS”; AND RECEIVING THE INTERNAL CONTROL

PROCEDURES MANUAL AND EXAMPLE RISK REGISTER
WHEREAS, on June 27, 2024, the San Mateo County Civil Grand Jury issued its report titled “Assessing and Reporting Internal Controls in San Mateo County Agencies and School Districts,” identifying that most agencies, including the City of East Palo Alto, do not formally document or assess internal controls or report assessment results to their governing boards; and WHEREAS, the Grand Jury issued three recommendations—R1 (Document organizational risks), R2 (Conduct an annual internal control assessment), and R3 (Report the results to the governing body and the public)—and the City submitted its response on September 17, 2024, agreeing in part with the findings and committing to implement an internal control framework grounded in the U.S.

Government Accountability Office’s Standards for Internal Control in the Federal Government (“Green Book”); and
WHEREAS, the City prepared a formal Internal Control Policy, which establishes the governing framework, expectations, and oversight structure for internal control management and sets forth the Council’s role in supporting a strong control environment; and WHEREAS, staff also prepared an Internal Control Procedures Manual and Example Citywide Risk Register, which provide operational guidance, templates, and documentation tools for identifying risks, evaluating internal controls, maintaining compliance with the Green Book and COSO frameworks, and supporting preparation of the Annual Internal Control Report; and WHEREAS, the Internal Control Policy is a Council-approved governing document, while the Procedures Manual and Risk Register are management tools that may be updated administratively by the City Manager or Finance Director to reflect organizational needs, system changes, or best practices; and
WHEREAS, implementation of the Internal Control Policy and Procedures Manual satisfies the Grand Jury’s recommendations by:
 Establishing a formal process for documenting organizational risks (R1);  Requiring annual assessments of internal controls and continuous improvement (R2); and  Providing for structured annual reporting to the City Council and public (R3); and WHEREAS, the City Council desires to approve the Internal Control Policy, accept the implementation framework, and receive and file the supporting internal control documents.

NOW, THEREFORE, BE IT RESOLVED THAT THE CITY COUNCIL OF THE CITY OF EAST PALO ALTO HEREBY:

1. Finds the foregoing recitals are true and correct, and are incorporated by this reference into this action; and
62 Resolution No. XX-2025 2 of 2

2. Approves the City of East Palo Alto Internal Control Policy, attached to the Staff Report as Attachment 2;

3. Accepts the implementation framework described in the Staff Report and established through the Internal Control Policy and Internal Control Procedures Manual, constituting the City’s formal response to the 2023–24 San Mateo County Civil Grand Jury Report “Assessing and Reporting Internal Controls”;

4. Receives the Internal Control Procedures Manual and Example Risk Register, attached to the Staff Report as Attachments 3 and 4, recognizing that these are management documents subject to administrative updates by the City Manager or Finance Director; and

5. Finds that the proposed action does not constitute a “project” with the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment.

PASSED AND ADOPTED this 16th day of December 2025, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

Martha Barragan, Mayor
ATTEST: APPROVED AS TO FORM:

James Colin, City Clerk John D. Lê, City Attorney
63 CITY OF EAST PALO ALTO
Internal Control Policy
December 16, 2025

1. Purpose
The purpose of this Internal Control Policy is to establish a structured, Citywide framework for designing, implementing, and maintaining effective internal controls that promote operational efficiency, ensure reliable financial reporting, safeguard public assets, support compliance with laws and regulations, and reinforce public trust in the City of East Palo Alto.

This Policy represents the City Council’s commitment to sound governance and accountability. It establishes the expectations and requirements that guide the City’s internal control environment.

2. Authority and Scope
This Policy is approved by the City Council and applies to all City departments, offices, divisions, programs, systems, and activities. Management is responsible for implementing this Policy and ensuring that internal controls are embedded in all work processes, systems, and decision-making activities.

This Policy may be amended only by City Council action.

Detailed procedures, templates, risk registers, and implementation tools are provided in the Internal Control Procedures Manual, a management document that may be updated periodically by the City Manager or Finance Director without Council approval.

3. Internal Control Framework
The City adopts the U.S. Government Accountability Office’s Standards for Internal Control in the Federal Government (GAO “Green Book”) as its foundational internal control framework. The Green Book is based on the Committee of Sponsoring Organizations of the Treadway Commission (COSO) model.
64 CITY OF EAST PALO ALTO
Internal Control Policy
December 16, 2025
The Green Book identifies five interrelated components of internal control:

1. Control Environment – Sets the organizational tone, establishes integrity and ethical values, and assigns authority, responsibility, and accountability.

2. Risk Assessment – Identifies, analyzes, and prioritizes risks related to achieving objectives.

3. Control Activities – Implements actions such as approvals, reconciliations, segregation of duties, and other procedures to mitigate risks.

4. Information and Communication – Ensures relevant, timely, and quality information is shared internally and externally to support control responsibilities.

5. Monitoring – Evaluates the effectiveness of internal controls over time and promptly addresses deficiencies.

These components provide a structure for integrating internal controls into all levels of City operations—including financial management, budgeting, procurement, payroll, technology, compliance, grants, and service delivery.

Internal controls provide reasonable assurance, recognizing that the cost of internal controls should not exceed the benefits derived and that absolute prevention of all errors or irregularities is not feasible.

4. Responsibilities
City Council
 Approves this Policy and any subsequent amendments.
 Provides oversight by reviewing annual internal control reports prepared by management.

City Manager
 Ensures management implements the requirements of this Policy. 65 CITY OF EAST PALO ALTO
Internal Control Policy
December 16, 2025
 Oversees development and maintenance of the Internal Control Procedures Manual.

Finance Director
 Leads the Citywide internal control program.
 Maintains the Risk Register, internal control assessment tools, and documentation standards.
 Coordinates the preparation of the Annual Internal Control Report.

Department Directors and Managers
 Implement internal controls within their areas of responsibility.  Identify and document risks, controls, and corrective actions.  Ensure staff are appropriately trained on internal control practices.

City Employees
 Follow established internal control procedures.
 Promptly report control deficiencies, irregularities, or noncompliance to management.

5. Risk Documentation
Management shall maintain an up-to-date Citywide Risk Register, including:
 Identification of risks across financial, operational, compliance, information technology, and reputational categories;
 Assessment of risk likelihood and potential impact;
 Assignment of departments responsible for managing particular risks;  Identification of risk control activities and corrective actions. 66 CITY OF EAST PALO ALTO
Internal Control Policy
December 16, 2025
Risk documentation must be updated annually, and whenever organizational or operational changes occur including events that materially affect workflows, internal controls, or how the City conducts its operations.

6. Annual Assessment of Internal Controls
Management shall perform a Citywide assessment of internal controls annually.

The assessment must:
 Evaluate whether identified risks are mitigated by effective control activities;  Determine whether controls are properly designed, implemented, and operating as intended;
 Identify control gaps or deficiencies requiring corrective action.

This assessment shall be coordinated by the Finance Director, with active participation from all departments.

7. Corrective Action Plans
When deficiencies are identified, management shall develop Corrective Action Plans (CAPs) that include:
 The nature of the deficiency;
 Actions needed to remediate it;
 Responsible staff or departments;
 Target completion dates; and
 Progress tracking.

CAPs must be monitored regularly until resolved.

8. Reporting Requirements
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Consistent with the Monitoring and Information & Communication components of the COSO/Green Book framework:
 Management shall prepare an Annual Internal Control Report for City Council review.
 The report shall summarize:
o Results of the annual assessment;
o Significant risks and control activities;
o Identified deficiencies and corrective actions;
o Progress toward continuous improvement (as defined below). o Updates to the Internal Control Procedures Manual.

The Annual Report serves as the City’s formal reporting mechanism and supports transparency and accountability in City operations.

9. Continuous Improvement
Internal controls are dynamic and must evolve with changes in staffing, technology, laws, organizational structure, and service delivery. Management shall continuously refine internal controls and update procedures in the Internal Control Procedures Manual to reflect emerging risks and best practices.
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1. Purpose and Relationship to Policy
This Internal Control Procedures Manual (“Manual”) provides the detailed processes, expectations, and tools necessary to implement the City of East Palo Alto Internal Control Policy (“Policy”).

The Policy sets forth the Council-approved requirements and overarching responsibilities.

This Manual provides operational guidance on how departments and staff meet those requirements.

This Manual may be updated administratively by the City Manager or Finance Director to reflect changes in organizational structure, technology, legal requirements, or best practices—without additional City Council action. In accordance with City Council approved Internal Control Policy (Section 8. Reporting Requirements), changes to this manual will be reflected in the Annual Internal Control Report.

2. Internal Control Framework
The City bases its internal control system on the U.S. Government Accountability Office’s Standards for Internal Control in the Federal Government (“Green Book”), which in turn incorporates the COSO Internal Control—Integrated Framework.

This ensures that the City's internal control environment is aligned with widely recognized professional standards and consistent with the framework referenced by the 2023–24 San Mateo County Civil Grand Jury Report.

The Green Book organizes internal control into five integrated components, supported by 17 principles, which together provide a comprehensive structure for designing, implementing, and evaluating internal controls.

The components and their roles within the City’s internal control system are described below.

2.1 Control Environment
The Control Environment is the foundation of the City’s internal control system. It establishes the tone, culture, and expectations that influence how staff carry out their responsibilities.

A strong control environment includes:
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 Clear assignment of authority and responsibility across departments.  Organizational structure that supports effective oversight.  Competent and well-trained personnel.
 Enforcement of standards of conduct and professional behavior.

This component sets the tone at all levels and creates the conditions that enable effective internal controls.

2.2 Risk Assessment
Risk Assessment involves identifying and analyzing internal and external risks that could prevent the City from achieving its objectives. It includes:
 Identifying risks to operations, reporting, compliance, IT, and financial management.  Evaluating the likelihood and impact of risks.
 Considering changes in staffing, systems, regulations, or conditions.  Assessing fraud risks, including opportunity, pressure, and rationalization.  Forming a basis for determining how identified risks should be mitigated.

This process is dynamic and must be updated periodically to reflect changing conditions and priorities.

2.3 Control Activities
Control Activities are the actions, procedures, and mechanisms in place to mitigate risks and ensure that directives are carried out. These include:
 Approvals, authorizations, and supervisory reviews.
 Reconciliations and verifications.
 Segregation of duties and access restrictions.
 System-enforced controls and automated validations.
 Policies, procedures, and documented workflows.
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Control Activities operate at all levels of the City—entity-wide, departmental, and processspecific—and are both preventive and detective in nature.

2.4 Information and Communication
Information and Communication ensure that relevant, accurate, and timely information is captured and communicated to support internal control responsibilities. Effective communication includes:
 Internal communication across departments and levels of management.  Clear dissemination of policies, procedures, and expectations.  Reliable data systems that support operations and reporting.  External communication with stakeholders, auditors, granting agencies, and the public.

This component ensures that staff have the information they need to perform their duties and that the City communicates effectively inside and outside the organization.

2.5 Monitoring Activities
Monitoring ensures that internal controls are present and functioning over time. It includes:
 Ongoing monitoring through daily supervisory activities.  Periodic evaluations through internal control assessments, audits, or reviews.  Identification and timely remediation of control deficiencies.  Verification that Corrective Action Plans (CAPs) are implemented effectively.  Continuous assessment of whether internal controls remain aligned with risks and changing operations.

Monitoring provides feedback on the effectiveness of internal controls and supports continuous improvement.

3. Foundational Internal Control Concepts
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To ensure a shared understanding of internal controls across the City, the following concepts apply to all departments.

3.1 Segregation of Duties
Segregation of duties reduces the risk of errors, misuse, or fraud by ensuring that no single individual controls all phases of a transaction. Duties involving:
 authorization,
 custody of assets,
 recordkeeping, and
 reconciliation
should be separated whenever feasible.

When staffing constraints prevent full separation, compensating controls (e.g., supervisory review or independent checks) must be implemented.

3.2 Types of Controls
Departments must maintain a mix of control types, including:
 Preventive controls (e.g., approvals, segregation of duties)  Detective controls (e.g., reconciliations, audits, exception reports)  Manual controls (performed by staff)
 Automated controls (system-enforced)
 Compensating controls (when ideal controls are not practical) Effective processes generally include both preventive and detective controls.

3.3 Fraud Risk Awareness (Fraud Triangle)
Fraud risk is generally present when three conditions exist:
 Opportunity to commit and conceal the act
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 Pressure or motive pushing the individual toward misconduct  Rationalization that justifies the behavior
Managers should incorporate fraud awareness into process design and regularly assess opportunities for misuse.

3.4 Documentation and Evidence Expectations
Staff must maintain documentation supporting control execution, including approvals, reconciliations, reviews, logs, audit trails, and system reports. Controls that are not documented are considered not performed.

3.5 Reasonable Assurance and Cost–Benefit Principle
Internal controls provide reasonable, not absolute, assurance. Departments should balance the cost and benefit of controls, ensuring that controls reduce risk without creating unnecessary administrative burden.

4. Roles and Responsibilities
City Manager
 Ensures implementation of the Policy and this Manual across departments.  Approves updates to this Manual.

Finance Director
 Leads the Citywide internal control program.
 Maintains Risk Register, assessment tools, and documentation standards.  Coordinates the Annual Internal Control Report.

Department Directors
 Establish control practices within their operations.
 Ensure staff comply with internal control requirements.

Supervisors and Managers
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 Implement controls in daily workflow.
 Monitor control performance and address deficiencies.

All City Employees
 Follow all internal control procedures.
 Report irregularities or suspected fraud promptly.

5. Risk Documentation Procedures

5.1 Annual Risk Identification
Each department must identify risks in the following categories:
 Financial
 Operational
 Compliance
 Information technology and cybersecurity
 Reputational (Risks that may harm the City’s public trust, credibility, or perceived integrity)

5.2 Risk Register
Departments must use the Citywide Risk Register Template (Appendix A) to document:
 Risk descriptions
 Likelihood and impact ratings
 Related Green Book principles
 Existing controls
 Gaps or weaknesses
 Corrective Actions Plans (if applicable)
 Responsible staff
 Target completion dates
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5.3 Updates
 Updated annually as part of the internal control assessment.  Updated immediately if significant operational or regulatory changes occur including events that materially affect workflows, internal controls, or how the City conducts its operations.

6. Internal Control Assessment Procedures

6.1 Assessment Scope
Annual assessments evaluate:
 Control design and effectiveness
 Segregation of duties
 Authorization protocols
 IT security and access
 Finance and operational compliance
 Corrective action progress
 Alignment with the Green Book’s 17 principles

6.2 Assessment Tools
The Risk Register (separate worksheet) serves as the single, comprehensive documentation tool for the City’s internal control assessment.

All assessment activities—including walkthroughs, interviews, documentation reviews, and evaluation of control design and effectiveness—must be recorded directly in the Risk Register.

Departments and the Finance team must use the Risk Register to document:
 Staff interviews, understanding the process and how related controls are designed and in place
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 Identification of deficiencies, identifying and documenting any deficiencies of controls  Corrective Action Plans, responsibility assignments, and timelines  Alignment with applicable COSO/Green Book principles
By consolidating all assessment information into a single document, the City ensures a clear, auditable, and complete record of the department’s internal control evaluation.

6.3 Assessment Steps

1. Finance issues guidance and timeline

2. Departments complete self-assessment and update Risk Register

3. Finance conducts evaluations and walkthroughs

4. Finance identifies deficiencies or improvement needs

5. Departments finalize Corrective Action Plans

6. Finance consolidates findings for the Annual Internal Control Report

7. Corrective Action Plan Procedures

7.1 When a CAP Is Required
A Corrective Action Plan (CAP) is required when a deficiency is identified in an assessment, audit, or evaluation.

7.2 CAP Components
Each CAP must include:
 Description of the deficiency
 Identification of the root cause of the deficiency
 Proposed corrective actions
 Responsible staff or department
 Target completion date
 Resource needs
 Status and closure documentation
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7.3 Monitoring
 Finance monitors CAPs quarterly
 Departments provide updates
 Significant, overdue, or high-risk CAPs are escalated to the City Manager

8. High-Level Overview of Controls for City Operational Areas

8.1 Cash Receipts
Effective cash receipting controls ensure accuracy, security, and complete recording of City revenues and other receipts. Controls should ensure that:
 All incoming payments are logged immediately using receipts, system entries, or collection logs.
 Cash and checks are secured in locked, access-controlled locations.  Collection, recording, and reconciliation duties are separated or supported by compensating controls.
 Deposits are made intact, timely, and verified by supervisors.  Regular reconciliations compare logs, system totals, and bank activity.  Voids, refunds, or adjustments receive documented supervisory review.  Electronic receipting systems maintain audit trails and appropriate access controls.

8.2 Accounts Payable (AP) / Cash Disbursements
Controls ensure only authorized and valid payments are made. Controls should ensure that:
 Invoices are accurate, supported, and matched to purchase orders and receiving documentation.
 Approval routing follows defined authority levels.
 A three-way match is performed before payment.
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 Vendor master file access is restricted to limited finance staff and changes are independently reviewed.
 Payments occur only after full documentation and review by finance management staff.  Voided checks or exceptions receive supervisory review and documentation.  Reconciliations compare AP records with the general ledger and banking activity.

8.3 Payroll
Payroll controls ensure accurate, authorized compensation. Controls should ensure that:
 Only employees in authorized positions are paid.
 Changes to pay or status are supported by approved personnel action forms (PAFs).  Timekeeping is accurate and reviewed by supervisors.
 Payroll duties (entry, calculation, authorization) are segregated.  Payroll registers are reviewed by finance management staff before final processing.  Terminated employees are removed promptly from the payroll system.  Payroll-related accounts are reconciled periodically

8.4 General Ledger & Financial Reporting
Controls ensure financial accuracy and compliance. Controls should ensure that:
 Journal entries are documented and approved independently.  Adjustments include clear explanations and supporting evidence.  Monthly reconciliations of key accounts are prepared and reviewed.  Financial reports undergo supervisory review for accuracy and reasonableness.  Period-end closing procedures are standardized and documented.  Significant variances or unusual trends are investigated.  Supporting documentation is retained in accordance with City retention schedules. 78 CITY OF EAST PALO ALTO
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8.5 Grants Management
Controls ensure compliance with grant requirements. Controls should ensure that:
 Award documents, terms, and compliance requirements are maintained and communicated.
 Expenditures charged to grants are allowable and properly documented.  Grant activity is tracked separately within the financial system.  Reimbursement requests include all required supporting documentation.  Departments coordinate with Finance on reporting and compliance.  Grant budgets are monitored regularly for variances.
 Audit requirements (including Single Audit) are understood and followed.

8.6 Treasury & Cash Management
Controls ensure safety, liquidity, and compliance. Controls should ensure that:
 Investment activities comply with the City’s Investment Policy and applicable law.  Duties related to authorization, processing, and recordkeeping are separated.  Electronic banking uses dual authorization and authentication controls.  Bank accounts are reconciled monthly, with discrepancies resolved.  Cash flow is forecasted to meet operational and debt obligations.  Access to banking systems is restricted and periodically reviewed by finance management staff.
 Documentation is retained for audit and oversight.

8.7 Procurement & Contracting
Controls ensure integrity and transparency in City purchasing. Controls should ensure that:
 All procurements comply with City policy and state and federal requirements. 79 CITY OF EAST PALO ALTO
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 Authority limits and approval requirements are followed.  Conflicts of interest are disclosed and avoided.
 Contracts undergo review for scope, pricing, insurance, and legal compliance.  Goods and services received are verified prior to payment approval.  Contract performance is monitored and documented.
 Procurement documentation is retained for transparency and audit.

8.8 Information Technology & Cybersecurity
Controls protect City systems and data. Controls should ensure that:
 User access aligns with job duties and is reviewed regularly.  Passwords and authentication comply with security standards.  System changes follow change-management procedures.
 Data backup and disaster recovery processes are tested periodically.  Cybersecurity threats are monitored and incidents are documented.  Physical and logical system access is restricted and monitored.  IT and cybersecurity risks are included in the Risk Register.

8.9 Compliance with Laws and Regulations
Controls ensure the City adheres to applicable laws, regulations, policies, and contract terms.

Controls should ensure that:
 Staff understand applicable legal and regulatory requirements.  Procedures reflect federal, state, and local laws; grant conditions; and adopted City policies.
 Regulatory changes are identified and incorporated promptly.  Transactions are documented to demonstrate compliance.  Supervisors review work to ensure adherence to legal and regulatory requirements. 80 CITY OF EAST PALO ALTO
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 Compliance risks are documented and addressed in the Risk Register.  Corrective Action Plans are developed promptly to resolve compliance deficiencies.  Compliance topics are included in staff training and internal communication.

8.10 Budgetary Control
Budgetary controls ensure that public funds are used in accordance with City Council appropriations, legal requirements, and adopted priorities. Controls should ensure that:
 City Council establishes appropriations and no expenditures exceed these amounts without authorized amendments or transfers.
 Departments routinely monitor their budgets to ensure spending aligns with approved funding levels and intended purposes.
 Budget-to-actual reports are reviewed by managers, with variances identified, explained, and resolved.
 Budget adjustments or transfers comply with City policy and include required approvals and documentation.
 Multi-year projects, grants, and capital programs are monitored to ensure consistency with approved budgets and funding sources.
 Position control ensures staffing levels and compensation remain aligned with authorized positions in the adopted budget.
 Financial forecasts and expenditure trends are reviewed to anticipate and address emerging risks or imbalances.
 Budgetary requirements—such as Gann Limit compliance, fund restrictions, and costrecovery mandates—are incorporated into monitoring processes.  Documentation supporting budget decisions and monitoring activities is retained for transparency and audit.
 Budget monitoring results inform the annual internal control assessment and Risk Register updates.

9. Documentation Standards
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Departments must maintain:
 Control evidence (logs, approvals, reconciliations)
 Delegation of authority documentation
 IT access and security documentation
 Financial and operational process instructions
 Required regulatory and grant compliance records
 Records in accordance with the City’s retention schedule Controls without documentation are considered incomplete.

10. Monitoring & Continuous Improvement
 Supervisors conduct day-to-day monitoring.
 Finance performs annual internal control assessments.  Monitoring results inform updates to procedures, training, and controls.  Controls evolve to address changing risks, technology, and regulations.

11. Annual Internal Control Report
 Finance prepares the Annual Internal Control Report summarizing assessment results, corrective action progress, and improvements.
 The City Manager reviews and approves the draft report.  The City Council annually reviews and approves the final report.  The report shall be publicly available for transparency. 82 Risk ID Risk Description Category Green Book Principle(s) Likelihood Impact Existing Controls Control Gaps Mitigation Plan / Actions Responsible Dept. Target Date Status R-AP-01 Unauthorized or duplicate vendor
payments in Accounts Payable
Financial Principle 10 – Control Activities;
Principle 8 – Fraud Risk Medium High Segregation of duties; 3-way match Limited monitoring of duplicate vendors Implement vendor master file review; quarterly AP audit Finance 12/31/2025 Open R-AP-02 Delays in vendor payments
affecting vendor relations Operational / Reputational Principle 12 – Control Activities Medium Medium Standard AP workflow No backup approver Cross-train staff; adopt deputy AP approver policy Finance 3/31/2025 In Progress R-CR-01 Theft or misappropriation of cash
receipting
Financial Principle 10 – Control Activities;
Principle 7 – Risk Identification Low High Cash drawer reconciliation; armored transport No surprise audits Introduce random cash counts by Finance Finance / Clerk 6/30/2025 Open R-CR-02 Delayed bank deposits of cash
receipts Financial Principle 16 – Monitoring Medium Medium Daily deposit policy Policy not consistently enforced Automate reconciliation; implement cash receipting system Finance / Treasury 12/31/2025 Open
R-PY-01
Inaccurate payroll processing (overtime miscalculation, miscoding) Financial / Compliance Principle 10 – Control Activities; Principle 15 – Reporting Medium High Payroll system controls; HR approval Lack of automated exception reporting Implement exception-based payroll audit HR / Finance 9/30/2025 Not Started R-PY-02 Unauthorized payroll changes
(ghost employees)
Fraud
Principle 8 – Fraud Risk; Principle 11 – Information & Communication Low High New hire/termination approvals No periodic user access audit Quarterly payroll master file reconciliation HR / Finance 12/31/2025 Open R-TR-01 Liquidity shortfall due to poor
cash forecasting
Financial Principle 6 – Define Objectives;
Principle 9 – Identify Change Medium High Monthly treasury reports Forecast not linked to CIP/budget Implement rolling cash forecast model Finance / Treasury 6/30/2025 Open R-FR-01
Material misstatements in financial reporting
Financial Principle 14 – Monitoring;
Principle 15 – Reporting Medium High Annual audit; CAFR prep Limited interim reporting Quarterly financial statement preparation Finance 3/31/2025 Open R-BD-01 Budget overruns due to
inadequate monitoring Financial / Operational Principle 6 – Define Objectives; Principle 14 – Monitoring Medium High Budget adoption; midyear review Lack of monthly variance reporting Implement monthly budget-to- actual reporting to CM Finance / City Manager 12/31/2025 Open R-GR-01
Noncompliance with federal
grant requirements (e.g., Uniform Guidance)
Compliance
Principle 17 – Remediation of Deficiencies; Principle 7 – Risk Identification Medium High Single Audit; grant manager reviews No centralized grants compliance log Establish centralized grants compliance calendar Finance / Depts. 9/30/2025 In Progress R-GR-02 Late submission of grant reports
leading to loss of funding Compliance / Reputational Principle 13 – Information & Communication Low High Department reporting No standardized deadlines Centralize reporting deadlines in City Clerk system Finance / Clerk 6/30/2025 Open R-IT-01 Unauthorized system access due
to weak user rights management IT / Security
Principle 11 – Information & Communication; Principle 12 – Control Activities High High IT account provisioning process No quarterly user access review Conduct quarterly user rights audit IT / Finance 3/31/2025 In Progress R-IT-02 Cyberattack due to poor
password practices IT / Security Principle 10 – Control Activities High High Password change policy No MFA requirement Enforce 12-char passwords + MFA IT 6/30/2025 Open R-IT-03 System downtime impacting
financial operations Operational Principle 16 – Monitoring Medium High Local backups No offsite/cloud redundancy Adopt cloud-based disaster recovery solution IT 12/31/2025 Not Started R-IT-04 Phishing attack leading to
ransomware
IT / Security
Principle 8 – Fraud Risk; Principle 13 – Information & Communication High High Spam filter; IT awareness training Training not mandatory Implement mandatory annual IT security training IT / HR 9/30/2025 Open 83 POLICY AND ACTION ITEM 9.3

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: December 16, 2025
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Orly Amey, Assistant to the City Manager
Jeff Liu, Police Chief
SUBJECT: Authorization to Award Five-Year Agreement to LAZ Parking to Provide Parking Enforcement and Staffing Services
Recommendation

1. Receive a presentation on the competitive procurement process leading to the recommendation to select LAZ Parking as the vendor to provide Parking Enforcement;

2. Provide staff direction on the preferred level of parking enforcement service (Baseline, Expanded, or Comprehensive 24-Hour Coverage); and

3. Adopt a Resolution:
a. Authorizing the City Manager to award, negotiate and execute a five-year agreement with LAZ Parking, in a form approved by the City Attorney, at the cost of the preferred level of parking enforcement service; and b. Finding the proposed action does not constitute a “project” with the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(5) in that it is a governmental administrative activity that will not result in direct or indirect changes in the environment.

Executive Summary
For parking enforcement, the City of East Palo Alto currently relies on Community Service Officers (CSOs), who split their time among multiple public-safety duties and cannot sustain consistent citywide parking enforcement. This lack of dedicated staffing has resulted in persistent community concerns regarding street sweeping compliance, abandoned vehicles, blocked driveways, and long-term on-street vehicle storage. 84 POLICY AND ACTION ITEM 9.3
The City issued a request for proposals (RFP) on October 14, 2025, seeking a qualified contractor to provide comprehensive parking enforcement and staffing services to expand the City’s capacity. Staff received, evaluated, and scored four proposals based on published selection criteria. Following evaluation and interviews, LAZ Parking emerged as the most qualified and responsive proposer, offering a high-quality, community-centered program with proven experience in neighboring jurisdictions. Staff recommends awarding the City’s parking enforcement contract to LAZ Parking and implementing a phased, ambassador-based rollout for the first month of service, consistent with the firm’s proposal.

If the City Council wishes to award to LAZ Parking, it will need to provide further direction to staff on which of three service levels to select: Baseline Service (daytime coverage), Expanded Coverage (flexibility in enforcement) or Comprehensive 24-Hour Coverage. Thereafter, staff would negotiate the contract, and then the vendor would begin implementation.

Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:
• Priority: Public Health, Safety, and Quality of Life
Background
Parking management remains one of East Palo Alto’s most visible and frequently raised concerns. Residents consistently cite issues such as long-term vehicle storage, blocked driveways, abandoned cars, and inconsistent street-sweeping compliance as quality-of-life and environmental impacts. These concerns have intensified in recent years as residential density has increased and more households rely on public streets for daily and overnight parking.

Currently, parking enforcement is performed by Community Service Officers (CSOs). CSOs are highly committed and deeply involved in community policing; they are responsible for a wide range of duties including general patrol, administrative support, and responding to traffic collisions, leaving little time for proactive parking enforcement. As a result, parking enforcement in East Palo Alto has been reactive, inconsistent, and primarily limited to street-sweeping operations. This staffing model does not address the volume or complexity of today’s parkingrelated concerns. Recognizing these limitations, the City Council included “Expand Parking Enforcement Capacity” as a priority project under the Fiscal Year 2025-2027 Work Plan.

Analysis
RFP Process
On October 14, 2025, the City issued an RFP seeking experienced firms to provide parking enforcement and staffing services. The RFP was posted on the City’s website and distributed to many firms who provide such services. By the November 17, 2025, submission deadline, the City received four proposals from parking enforcement firms. Each proposal was evaluated using 85 POLICY AND ACTION ITEM 9.3
the selection criteria outlined in the RFP:
• Approach and Work Plan (20 points)
• Firm & Team Qualifications (20 points)
• References (20 points)
• Responsiveness & Service Quality (20 points)
• Cost Proposal (10 points)
The attached rubric was developed to delineate each criteria further. Two Police Captains and an Assistant to the City Manager reviewed all four proposals using a standardized scoring rubric based on the foregoing selection criteria. LAZ Parking, the highest-rated firm was invited to participate in an interview conducted on December 10, 2025, allowing the panel to further assess the firm’s understanding of and approach to the City’s needs.

Recommended Contract Award
Following proposal review and interviews, staff identified LAZ Parking as the most qualified, costeffective, and operationally prepared proposer. LAZ Parking provides municipal parking enforcement in communities across Northern California, including Palo Alto, San Mateo, San Bruno, Salinas, South San Francisco, and San Leandro. Its proposal demonstrates strong familiarity with the enforcement needs of high-density residential communities, as well as alignment with the City’s expectations for a service model that is fair, community-oriented, and focused on behavior change, as opposed to volume of citations issued.

As part of the evaluation process, staff also conducted reference checks with the Police Departments in San Mateo and South San Francisco. Both agencies spoke highly of LAZ Parking’s professionalism, responsiveness, and operational reliability, and strongly recommended the firm. These departments also provided valuable operational insights regarding deployment and communication, which reinforced staff’s confidence in LAZ Parking’s ability to meet East Palo Alto’s needs.

Of the four proposals received, two were deemed non-responsive. One proposal focused primarily on airport and ground-transportation services and did not demonstrate the capacity to perform the municipal parking enforcement scope outlined in the RFP. The second nonresponsive proposal was geared toward implementing a paid parking system with meters and permitting infrastructure, which does not align with the City’s current needs or policy direction.

A third proposal, submitted by the second highest-rated proposer, demonstrated that the firm was capable of performing the required scope of work. However, the firm has limited experience providing parking enforcement services in San Mateo County, and its proposed cost was not competitive—more than twice as expensive as the top proposer. As a result, while technically responsive, the proposal did not represent the best value for the City.

Based on its strong qualifications, competitive pricing, and relevant operational experience, staff recommends LAZ Parking as the most suitable vendor to deliver the Parking Enforcement and Staffing Services program.
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LAZ Parking employs a “community-first enforcement philosophy,” and its Ambassador Program model, described below, will support cleaner streets, predictable coverage, and responsive neighborhood service during early implementation of the parking enforcement program. This model prioritizes education and voluntary compliance.

Operational Model and Patrol Approach
LAZ Parking’s operational model is built around a beat-based deployment strategy (using EPA PD’s pre-existing beats), which would establish clearly defined geographic patrol zones throughout the City. Each beat is patrolled proactively every day under baseline service, with complaint-driven enforcement layered on top. LAZ Parking’s mobile-friendly complaint submission form is included at no extra cost in its model.

Under all service levels, the program includes: GPS-enabled hybrid vehicles with Samsara telematics to verify beat coverage; officers equipped with TurboData handheld citation issuance devices and body cameras; structured supervisory oversight, including daily audits and joint reviews with City staff; and a partnership model with EPAPD to ensure enforcement aligns with community expectations. LAZ Parking is prepared to work closely with EPAPD to deliver consistent, visible, and trusted enforcement across all neighborhoods.

Community Education and Ambassador-Style Rollout
A core component of LAZ Parking’s approach, and one of the elements that most clearly distinguishes its proposal, is the structure and function of the Ambassador Program, which is designed to introduce the City’s new parking enforcement services in a community-centered, educational, and non-punitive manner. The Ambassador Program is included at no extra cost and reflects LAZ’s “community-first enforcement philosophy” described in its proposal and interview. This Program is intended to establish trust, reduce confusion, and support voluntary compliance before the formal enforcement period begins.

Under this program, LAZ Parking deploys trained staff into the community approximately one month prior to the start of citation enforcement, at no additional cost to the City. These ambassador personnel are uniformed but do not issue citations. Instead, their role is to serve as the public-facing introduction to the program, helping residents and businesses understand what to expect, why the City is implementing contracted enforcement, and how the upcoming changes will affect daily parking habits. Ambassadors spend this period conducting outreach on foot and in vehicles, distributing educational materials, answering questions, and providing clear explanations of the parking rules most relevant to each neighborhood such as street sweeping times, red and yellow curb restrictions, blocked driveways, safety hazards, and common violations that currently generate complaints.

The Ambassador Program also allows LAZ Parking and City staff to jointly observe patterns of behavior, identify chronic problem locations, and refine beat configurations prior to issuing citations. This early presence creates an opportunity to build rapport with residents, reduce anxiety or misconceptions about enforcement, and establish a culture of fairness and clarity 87 POLICY AND ACTION ITEM 9.3
around the new system. Because Ambassadors document what they see in the field, the City also receives early insight into operational needs and community readiness, which helps ensure a smoother transition into full implementation.

The Ambassador Program advances the City’s objective of reducing parking complaints by focusing on education first. By providing warnings, guidance, and in-person explanations rather than immediate punitive action, the City signals that the purpose of the program is to improve neighborhood accessibility and quality of life, not to generate citation revenue. This method aligns with Council’s preference for determining program success through community outcomes rather than citation volume.

In addition to the one-month early rollout, LAZ also provides “Parking Checkup Days” during the first months of enforcement, another no-cost enhancement. These events allow LAZ Parking and City staff to visit problem areas together, answer resident questions, reinforce the educational messaging, and visibly demonstrate the City’s commitment to transparency and responsiveness.

Through this structured and proactive approach, the Ambassador Program serves as a bridge between historic enforcement practices and the new contracted model. It helps ease the community into the transition, ensures residents feel informed and respected, and lays the groundwork for stable, trusted, and effective enforcement over the long term.

Fixed-Fee Cost Structure
LAZ Parking proposes a fully inclusive, fixed annual fee for each service level that includes:
• All labor and supervision
• New hybrid enforcement vehicles equipped with GPS and Samsara telematics • TurboData-integrated handheld devices that integrate with existing technology used by the City’s Police Department
• Uniforms and officer body cameras
• Training and safety equipment
• Fuel, vehicle maintenance, insurance, and technology replacement LAZ Parking’s fixed-fee cost structure model ensures that the City will not see add-on charges for operational items, providing the City long-term budget predictability and reduction of administrative burden. Laz Parking’s quote for five-year pricing includes an annual increase of 3% cost of living adjustment (COLA) in service years two through five, reflecting current Bay Area labor conditions. Annual cost details are provided below for the three service levels.

Service Level Options
As requested in the RFP, LAZ Parking has provided three service level options, which correspond to different degrees of enforcement presence and community impact. Council direction is required to select a preferred level.
88 POLICY AND ACTION ITEM 9.3
Option 1. Baseline Service
The Baseline service level includes:
• Daytime coverage (M–F, roughly 8 a.m.–6 p.m.)
• Daily beat patrols
• Two-hour complaint response during service hours
• All technology, vehicles, supervision, and equipment
Baseline service addresses Citywide daytime parking enforcement needs but does not include evening, overnight, or weekend enforcement. As such, the program may have limited impact on chronic nighttime storage including commercial vehicle storage complaints, driveway blockages occurring after hours, and weekend congestion.

Under the supplemental cost proposal, the Baseline Service level includes fixed annual pricing with a 3% COLA applied annually in Years 2 through 5. The pricing for this service level is as follows:
• Year 1: $209,684
• Year 2: $215,975
• Year 3: $222,454
• Year 4: $229,128
• Year 5: $236,002
FIVE-YEAR TOTAL: $1,113,243
Rationale: Dedicated coverage more than doubles current enforcement hours, producing a sustainable increase in enforcement visibility and compliance.

Option 2. Expanded Coverage
The Expanded Coverage service level includes all elements of Baseline Service, including daily beat patrols, weekday enforcement aligned with core parking regulations, and complaint response standards. Under this option, the City would not lose any baseline enforcement functions.

What differentiates Expanded Coverage is how enforcement hours are deployed, not the overall scope of services. Expanded Coverage allows the City to reallocate a portion of standard weekday enforcement hours to address early morning, evening, or weekend periods, which have been identified as the City’s most common parking complaint windows.

Under this model, the City would work directly with LAZ Parking to design and direct the enforcement schedule based on local priorities. For example, the City could elect to:
• Shift enforcement start times for one Parking Enforcement Officer later on certain weekdays to extend coverage into the evening; or
89 POLICY AND ACTION ITEM 9.3
• Reallocate one Parking Enforcement Officer’s weekday shift to provide targeted weekend enforcement, such as on Saturdays.

These adjustments would be implemented within the fixed annual cost for Expanded Coverage and would not increase total staffing levels beyond those included in this service tier.

As a result, Expanded Coverage involves tradeoffs rather than additions. While the City would gain enforcement presence during higher-impact periods determined by the City, coverage during some standard weekday hours may be reduced or redistributed. This option is intended to potentially address Council’s desire to address parking issues that occur outside traditional business hours, without moving to the comprehensive 24-hour enforcement service level.

LAZ identifies this service level as a flat-rate annual cost that does not increase in Years 2–5, making it the only service level without COLA adjustments. The pricing for this service level is:
• Year 1: $301,616
• Year 2: $301,616
• Year 3: $301,616
• Year 4: $301,616
• Year 5: $301,616
FIVE-YEAR TOTAL: $1,508,080
Rationale: The expanded coverage window captures AM peaks, PM congestion, and consistent school-area and street sweeping enforcement, all of which historically generate higher violation counts.

Option 3. Comprehensive 24-Hour Coverage
The Comprehensive 24-Hour Coverage service level includes:
• Continuous 24/7 enforcement
• Full evening, overnight, and weekend coverage
• Highest level of responsiveness and deterrence of undesirable parking behaviors This service level represents the highest operational impact, offering complete coverage of all hours and all neighborhoods, and the most robust response to chronic parking concerns. This service level option may be appropriate if Council desires an overtly transformative approach to parking behavior.

The Comprehensive Coverage level includes a full 24-hour enforcement model with staffing and equipment necessary for continuous operations. The supplemental proposal applies a 3% COLA each subsequent year. Pricing for this level is:
• Year 1: $396,467
• Year 2: $408,362
90 POLICY AND ACTION ITEM 9.3
• Year 3: $420,612
• Year 4: $433,231
• Year 5: $446,228
FIVE-YEAR TOTAL: $2,104,900
Rationale: Comprehensive coverage enables overnight enforcement, abandoned vehicle identification, chronic violator detection, and expanded complaint response, all of which materially increase citation volume and compliance.

Table: Service Level Summary
Service Level
Fixed
Monthly
Y1 Cost
Fixed Y1
Cost
Annual
PEO
Hours
Staffing
Structure
Coverage
Approach
Option 1:

Baseline
Service
$17,474
$209,684
(+3% in
Y2-Y5)
3,840
One Parking
Enforcement
Officer (PEO)
per shift;
regional
Supervisor
oversight
Weekday coverage
aligned with primary
enforcement hours;
daily beat patrol
requirements
Option 2:

Expanded
Coverage
$25,135 $301,616 5,760
Up to two PEOs
per day + one
Supervisor
Expanded weekday
coverage with
flexibility for limited
weekend
enforcement as
directed
Option 3:

Comprehensive
24-Hour
Coverage
$33,039
$396,467
(+3% in
Y2-Y5)
7,680
Continuous
PEO staffing for
around-theclock
enforcement (4
PEOs),
including one
Supervisor
Full 24-hour
enforcement
capability, supporting
proactive patrols and
rapid response to
overnight issues and
complaints
Future Potential ALPR Units, if Any, Would Have to Return to City Council LAZ Parking also offered Automated License Plate Reader units at the cost of a $11,000 annual subscription and $25,000 per unit. ALPRs are vehicle-, stoplight- or private-property mounted high-speed cameras that scan license plates and may share that information across jurisdictions.

At this time, due to voiced community privacy implications, staff is not requesting to incorporate 91 POLICY AND ACTION ITEM 9.3
the ALPR technology features into the contract. Should the City wish to entertain this option in the future, this would require a contract amendment, which must return to the City Council per the City’s purchasing ordinance.

The Metrics of Success Focus on Improving Quality of Life, Not on Generating Citations Citation volume should not be used as a success metric, as it can create a perception of quotabased enforcement, which is neither desirable nor recommended. Instead, alternate metrics of success are:
• Reduction in parking-related complaints
• Reduction in long-term stored vehicles
• Improvement in street sweeping compliance
• Two-hour complaint response compliance
• Verified beat coverage through telematics
• Community satisfaction and reduction in repeat issues These metrics reflect the program’s core objective: improving quality of life for residents, not generating citations.

The Implementation Timeline
The transition to full parking enforcement services follows a structured, phased schedule designed to move from initial planning to full deployment with minimal disruption to the community. Although the sequence can be adjusted to meet the City’s preferred timelines, LAZ Parking outlines a typical eight-week ramp-up period following contract execution that ensures officers, equipment, and operational systems are fully prepared before formal enforcement begins.

During the initial phase of implementation, LAZ Parking anticipates executing the contract and holding a formal kickoff meeting with EPAPD and City staff. This early phase focuses on confirming program goals, the selected service level, and the reporting expectations that will guide ongoing oversight. LAZ Parking will review existing enforcement practices in East Palo Alto, evaluate current TurboData configurations, and examine any existing beat maps that may inform deployment. This initial review establishes the operational foundation and ensures alignment between the City and LAZ before field activities begin.

In the following two weeks, LAZ Parking expects to begin recruiting and conditionally hiring the Parking Enforcement Officers and onsite Supervisor who will staff the program. This includes preliminary screening consistent with LAZ’s municipal hiring standards. LAZ Parking has confirmed its ability to recruit locally within East Palo Alto and has expressed interest in hosting a local job fair in East Palo Alto, in coordination with the City, to support local hiring. Priority would be given to qualified City residents, consistent with applicable hiring requirements. At the same time, LAZ Parking will begin ordering and configuring the uniforms, hybrid enforcement vehicles, handheld devices, radios, and GPS-based telematics tools that are included in the City’s fixed fee structure. LAZ Parking will also draft the post orders, deployment plans, and 92 POLICY AND ACTION ITEM 9.3
complaint-handling protocols that will govern day-to-day operations once enforcement begins.

The following two weeks are dedicated to completing the full background checks, psychological evaluations, medical clearances, and other requirements necessary to ensure all staff meet EPAPD standards. Officers will undergo approximately forty hours of initial training covering the East Palo Alto Police Department Parking Enforcement Training Manual, the East Palo Alto Municipal Code, the California Vehicle Code, customer service principles, safety practices, and the geography of the City. During this phase, officers will participate in ride-alongs and field coaching with experienced LAZ Parking personnel from other municipal programs in the region, allowing them to observe best practices in real-world settings before beginning operations in East Palo Alto.

In the last two weeks before full deployment, LAZ Parking plans to initiate an enforcement soft launch. In this period, hours of enforcement will be limited and supervisor presence will be heightened, allowing LAZ Parking to test route designs, confirm the effectiveness of GPS tracking and other technologies, and refine the program’s complaint-handling workflows. LAZ Parking will also finalize the configuration of TurboData reporting tools, GPS dashboards, and performance metrics that will be used to track program outcomes. At the end of this period, full deployment will begin at the service level selected by the City Council, with daily proactive enforcement across all beats and a two-hour response time for complaint-driven calls.

Throughout all phases of the transition, LAZ Parking will coordinate closely with EPAPD on messaging to the community, particularly around street sweeping rules, school zones, and any known hotspot areas. This close coordination ensures that enforcement begins in a consistent, predictable, and community-centered manner, reinforcing the City’s intent to improve neighborhood quality of life and reduce parking-related complaints.

Office Space and Operational Workspace Requirements
To ensure seamless coordination between the contractor and the City, LAZ Parking will require access to designated workspace within East Palo Alto to support day-to-day operations, supervisor oversight, equipment storage, and reporting functions. Although LAZ Parking provides all staffing, vehicles, uniforms, and technology as part of the fully inclusive cost structure, the proposal anticipates close alignment with EPAPD and City staff, which necessitates a local operational footprint.

Under the proposed model, LAZ Parking will utilize office space provided by the City for its onsite Supervisor and, as needed, Parking Enforcement Officers at the start and end of their shifts.

This space will serve as the central location for daily briefings, deployment planning, document management, report preparation, and coordination with EPAPD. Because LAZ Parking will provide and maintain all enforcement vehicles off-site, no dedicated vehicle storage is required on City property beyond short-term staging.

Enforcement Authority and City Oversight
To ensure appropriate checks on the contractor’s enforcement authority, the Police Department 93 POLICY AND ACTION ITEM 9.3
will continue to retain full responsibility for all decisions related to towing and all administrative citation and towing appeals. While LAZ Parking will be authorized to issue parking citations and, when appropriate, leave notices advising that a vehicle may be subject to tow under the City’s existing policy, the authority to initiate or approve any tow will remain solely with EPAPD. This separation preserves due process protections and ensures that any enforcement action resulting in vehicle removal is subject to direct City oversight.

In addition, all administrative review processes for contested citations will continue to be managed by the City. LAZ Parking’s role will be limited to documentation of observed violations, and all enforcement must adhere to City policies. These controls ensure that final decisionmaking authority remains with the City and that contracted enforcement activities operate within clearly defined boundaries.

Fiscal Impact
The FY 2025-26 Adopted Budget includes $350,000 in the General Fund for the provision of parking enforcement and staffing services. The fiscal impact will depend on Council’s selection of service level. Annual pricing for each service level is summarized earlier in this report. City Council will need to appropriate additional funding for the services in subsequent fiscal years.

South San Francisco Police reported overall enforcement activity increased by approximately 300% within the first year of contracting with LAZ. They were able to redirect approximately $30,000 in existing resources that had previously supported parking enforcement-related staffing. While staff anticipates the City of East Palo Alto would also experience an increase in enforcement activity, it is not clear how high this increase would be or its associated fiscal impacts. We will not be using such funding for staffing reductions as we do not have dedicated parking enforcement staffing, but perhaps some of these funds can be used to offset LAZ’s cost.

At this time, staff cannot forecast such an offset with any certainty.

Public Notice
The public was provided notice by making the agenda and report available on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto.

Environmental
The action being considered does not constitute a “Project” within the meaning of the California Environmental Quality Act (CEQA), pursuant to CEQA Guideline section 15378 (b)(5), in that it is a government administrative activity that will not result in direct or indirect changes in the environment. Additionally, as a separate and independent basis, the proposed action being considered by the City Council is exempt from the CEQA because it entails the implementation of a parking management program that would permit the sweeping of streets, an important aspect of the City’s stormwater management program, and as such protects the environment by removing contaminants that would otherwise be discharged to the Bay. (CEQA Guideline section 15308).
94 POLICY AND ACTION ITEM 9.3
Government Code § 84308
Applicability of Levine Act: No, as the proposed action involves a contract that was competitively bid.

Analysis of Levine Act Compliance: Not applicable.

Attachments

1. Resolution

2. Scoring Rubric

3. Proposal of Recommended Consultant
95 Resolution No. XX-2025 1 of 3
RESOLUTION NO. XX– 2025

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO

SELECTING LAZ PARKING AS THE VENDOR TO PROVIDE PARKING
ENFORCEMENT AND STAFFING SERVICES; PROVIDING DIRECTION ON SERVICE LEVEL, OPTIONAL ENHANCEMENTS, AND METRICS OF SUCCESS; AUTHORIZING

THE CITY MANAGER TO AWARD, NEGOTIATE AND EXECUTE AN AGREEMENT WITH LAZ PARKING IN A FORM APPROVED BY THE CITY ATTORNEY; AND

FINDING THAT THE ACTION IS NOT A PROJECT UNDER CEQA GUIDELINES SECTION 15378(B)(5)
WHEREAS, the Fiscal Year 2025–27 City Council Work Plan identifies “Expand Parking Enforcement Capacity” as a priority project intended to improve neighborhood livability, strengthen compliance with parking regulations, and reduce long-term vehicle storage and related safety impacts throughout the City; and
WHEREAS, the City currently relies on Community Service Officers to conduct parking enforcement, but their limited availability and multiple competing responsibilities prevent consistent citywide enforcement coverage; and
WHEREAS, in response to these operational challenges and consistent with Council direction, City staff issued a Request for Proposals (“RFP”) on October 14, 2025, seeking qualified firms to provide dedicated Parking Enforcement and Staffing Services; and WHEREAS, by the proposal deadline of November 17, 2025, the City received four proposals, which were evaluated in accordance with the selection criteria established in the RFP, including approach, work plan, team qualifications, references, responsiveness, service quality, and cost; and WHEREAS, following evaluation and interviews with the highest-rated proposer, staff determined that LAZ Parking is the most qualified and responsive firm to deliver the Parking Enforcement and Staffing Services described in the RFP; and WHEREAS, the City Council is being asked to select a preferred vendor and to provide direction regarding the appropriate level of service for the parking enforcement program, including whether to implement Baseline Service, Expanded Coverage, or Comprehensive 24-Hour Coverage; and WHEREAS, the City Council is further being asked to provide direction regarding optional program enhancements offered by LAZ Parking, such as technology upgrades, outreach tools, or reporting enhancements, as well as the Council’s preferred metrics of success for evaluating parking program performance; and
WHEREAS, upon receiving Council direction on these policy items, staff will finalize the scope of work and contract terms with LAZ Parking for execution by the City Manager; and WHEREAS, the proposed action consists solely of governmental administrative activities and will not result in direct or indirect physical changes to the environment and therefore does not constitute a “project” under the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines section 15378(b)(5).
96 Resolution No. XX-2025 2 of 3

NOW, THEREFORE, BE IT RESOLVED THAT THE CITY COUNCIL OF THE CITY OF EAST PALO ALTO HEREBY:

1. Finds the foregoing recitals true and correct and incorporated by reference into this action; and

2. Selects LAZ Parking as the vendor to provide Parking Enforcement and Staffing Services pursuant to the results of the competitive procurement process; and

3. Provides direction on the preferred level of service for the parking enforcement program, whether Baseline Service, Expanded Coverage, or Comprehensive 24-Hour Coverage; and

4. Provides direction on optional program enhancements offered by LAZ Parking for inclusion in the negotiated scope of work; and

5. Provides direction on the Council’s desired metrics of success for administration and evaluation of the parking enforcement program; and

6. Authorizes the City Manager to award, negotiate, and execute an agreement with LAZ Parking, in a form approved by the City Attorney, consistent with the Council’s selected service level, optional enhancements, and performance metrics; and

7. Finds action being considered does not constitute a “Project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines section (a) 15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment; and (b) 15308 as it entails the implementation of a parking management program that would permit the sweeping of streets, an important aspect of the City’s stormwater management program, and as such protects the environment by removing contaminants that would otherwise be discharged to the Bay.

PASSED AND ADOPTED this 16th day of December 2025, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

Webster Lincoln, Mayor
97 Resolution No. XX-2025 3 of 3
ATTEST: APPROVED AS TO FORM:

James Colin, City Clerk John D. Lê, City Attorney
98 Criteria Points
Possible
Points
Awarded
1 Well-thought-out and
Feasible Approach
and Work Plan
30 Assign 0-5 points (insufficient) if the
proposal: does not present a coherent or
feasible plan for delivering the Scope of
Work. Proposals in this range may lack a
clear methodology for proactive patrols,
complaint-driven response, street sweeping
enforcement, or neighborhood concerns.

They may fail to explain staffing levels, beat
structures, service levels (baseline,
extended, 24/7), or communication protocols
with EPAPD. Little or no detail is provided
about reporting tools, integration with City
systems (e.g., TurboData), or
implementation timelines.

Overall, these proposals do not demonstrate
understanding of EPA’s enforcement
environment or operational requirements.

Proposals in this range may also lack a
realistic implementation schedule,
communication plan, or any meaningful
detail about how the firm will manage or
perform the required services.

Assign 6-15 points (basic) if the proposal:
offers a general enforcement methodology but
lacks detail or EPA-specific tailoring. These
proposals may outline patrol routines or
complaint response processes but do not fully
address the City’s expectations for daily
proactive patrols, two-hour complaint response,
street sweeping coverage, or technology use
(ALPR, GPS, digital evidence capture). Staffing
plans and service levels may be only partially
developed. Reporting processes may be
described at a high level without clear
workflows. Implementation schedules may
appear workable but lack detail necessary for
confidence.

While the proposer may reference baseline
enforcement activities, the approach is only
partially developed and may not reflect a full
understanding of the City’s operational needs
or expectations.

These proposals generally demonstrate
feasibility but lack the specificity needed for full
confidence in execution.

Assign 16-25 points (competent) if the
proposal: presents a clear and well-organized
methodology directly responsive to EPA’s
needs.

These proposals articulate proactive daily
patrols of all beats, reliable complaint-driven
response, consistent street sweeping
enforcement, and procedures for addressing
abandoned vehicles and neighborhood
concerns. They include detailed staffing
structures, deployment plans, and daily/weekly
schedules. Proposers provide solid
communication protocols with EPAPD,
describe use of required technology
(TurboData, GPS tracking, photographic
evidence), and explain performance
monitoring. Implementation milestones and
transition plans are realistic and well
supported.

The work plan is feasible, the methodology is
sound, and the proposer demonstrates
readiness to implement the program
effectively.

Assign 26-30 points (comprehensive) if the
proposal: provides a highly detailed, fully
customized, and comprehensive approach that
reflects exceptional understanding of EPA’s
enforcement priorities.

These proposals include robust methodologies for
proactive and reactive enforcement, strong
supervisory structures, advanced reporting tools or
dashboards, and seamless integration with City
systems. They clearly demonstrate the ability to
provide baseline, extended, and 24/7 service
models; propose refined beat structures and
deployment plans; and detail complaint
management processes under City-monitored,
vendor-hosted, or hybrid models. Implementation
plans include clear timelines, onboarding, training,
and data integration steps.

Overall, these proposals inspire the highest
confidence in the proposer’s ability to deliver highquality, community-responsive enforcement ____
2 Experienced and
Qualified Firm &
Team
20 Assign 0-5 points (insufficient) if: the
proposer lacks demonstrated experience
providing municipal parking enforcement
services or provides insufficient information
about key personnel. Proposals in this range
may lack relevant California experience,
show no history with street sweeping
enforcement or abandoned vehicle
response, or fail to demonstrate ability to
recruit staff who meet the City’s strict
screening standards (background checks,
CLETS, polygraph, psychological exam).

Supervisory and officer qualifications may
be unclear or incomplete. Prior municipal
experience may be minimal.

Assign 6-12 points (basic) if: the proposer
demonstrates some relevant experience but
not at a level comparable to EPA’s needs.

Proposals may show partial experience with
municipal enforcement, but limited experience
with street sweeping programs, complaintdriven service, or neighborhood patrols.

Staffing qualifications may be adequate but not
strong across all roles.

Experience working with California jurisdictions
may be present but not extensive. The
proposer may demonstrate acceptable capacity
to recruit and retain staff but with limited
supporting evidence.

Assign 13-17 points (competent) if: the
proposer demonstrates solid and relevant
experience delivering parking enforcement
services to California jurisdictions of
comparable size and complexity.

These proposals include experienced
supervisory personnel, trained enforcement
officers, and demonstrated success with
proactive patrols, street sweeping, abandoned
vehicle response, and neighborhood
complaint resolution. The proposer shows
understanding of California Vehicle Code
requirements, municipal operations, and
customer-service expectations. Strong
personnel qualifications and credible
recruitment/retention strategies are evident.

Assign 18-20 points (exceptional) if: the proposer
demonstrates extensive, high-quality experience
delivering municipal parking enforcement services,
ideally in multiple California jurisdictions with high
residential density and significant complaint
volume. Key personnel possess exceptional
qualifications, supervisory structure is robust, and
recruitment/retention strategies are well developed
and credible.

The proposer has a proven record of managing
complex enforcement programs, integrating
technology (ALPR, GPS, reporting systems), and
delivering high-quality, community-oriented service.

These proposals show exceptional readiness and
capacity.
____
Scoring Proposals for Parking Enforcement and Staffing Services Proposer: ___________________________ Scorer: _______________________ Date: ____________ Attachment 2: Scoring Rubric
99 3 References 20
Assign 0–5 points (insufficient) if: the
proposer provides fewer than the required
three references, provides references that
are not local government agencies, or
provides references that do not reflect work
similar to the services required in this RFP.

Proposals in this range may also include
references with incomplete contact
information or vague descriptions of the
services performed. Feedback from
references, if reachable, may indicate
concerns with reliability, responsiveness,
communication, or overall service quality.

Assign 6–12 points (basic) if: the proposer
provides the required references but they
reflect only partially comparable experience or
limited depth in municipal parking enforcement.

References in this range may confirm generally
adequate performance but describe mixed
levels of service consistency, complaint
response, reporting accuracy, or
communication with agency staff.

While the proposer has demonstrated relevant
experience, past performance does not clearly
establish the ability to meet EPA’s service
expectations.

Assign 13–17 points (good) if: the proposer
provides complete and relevant references
demonstrating strong performance delivering
municipal enforcement or related services
within the past five years. Prior clients report
reliable enforcement, timely complaint
response, professionalism, strong
communication, and consistent reporting.

References corroborate the proposer’s
capabilities in street sweeping enforcement,
neighborhood concerns, abandoned vehicle
programs, or proactive patrols. Feedback
provides solid confidence that the proposer
can perform the required work in EPA.

Assign 18–20 points (exceptional) if: the
proposer provides strong and fully comparable
references from local government clients that
clearly demonstrate a high level of performance,
consistency, and reliability.

References in this range uniformly report excellent
service quality, proactive communication, accurate
and timely reporting, strong customer service
standards, and effective problem resolution.

References may indicate long-standing
partnerships, contract renewals, or high
satisfaction levels based on reliability,
professionalism, and accountability.

These references provide the highest degree of
assurance that the proposer will deliver
outstanding service to East Palo Alto.
____
4 Responsiveness &
Service Quality 20
Assign 0–5 points (insufficient) if: the
proposal fails to include all required
information or provides minimal detail
regarding service quality, responsiveness,
customer service philosophy, or reporting
tools.

Proposals in this range do not demonstrate
an understanding of EPA’s expectations
related to communication, community
responsiveness, or complaint tracking.

Assign 6–12 points (basic) if: the proposal
addresses most RFP requirements but
provides limited detail about customer service,
community responsiveness, complaint tracking,
or communication processes. Reporting
systems may be referenced but without
sufficient explanation of how they support daily
operations, complaint management, or monthly
reporting to EPAPD. The proposer may meet
minimum expectations but not clearly
demonstrate high-quality service delivery.

Assign 13–17 points (good) if: the proposal
clearly describes strong customer service
practices, complaint tracking systems,
communication protocols with EPAPD, and
reporting tools that support service monitoring.

Proposals in this range describe staff training
in community engagement, responsiveness to
resident concerns, and professional conduct.

Reporting tools appear adequate, userfriendly, and supportive of City oversight.

Assign 18–20 points (exceptional) if: the
proposal demonstrates a comprehensive and fully
integrated service quality framework, including
advanced reporting tools, real-time tracking, strong
customer service philosophy, proactive
communication with EPAPD, and well-developed
protocols for complaint intake, documentation, and
resolution.

These proposals demonstrate exceptional
responsiveness and strong alignment with EPA’s
expectation for community-focused enforcement.
5 Cost Proposal 10
Assign 0–2 points (insufficient) if: the cost
proposal is unclear, incomplete, inconsistent
with the staffing plan, or missing required
pricing for baseline, extended, or 24/7
service levels.

Pricing may appear unrealistic or not
reflective of the described operational
approach.

Assign 3–6 points (basic) if: the proposer
provides a complete cost proposal but lacks
transparency in cost assumptions, or if pricing
is only partially aligned with staffing plans or
service levels.

Pricing may be generally reasonable but fail to
provide detailed justification or is not fully
aligned with the methodology and staffing plan.

Assign 7–9 points (good) if: the cost
proposal is well structured, transparent, and
consistent with the staffing and service plan.

Pricing is competitive and reasonably reflects
a cost-efficient approach to delivering the
required services.

Assign 10 points (exceptional) if: the cost
proposal is comprehensive, transparent, and
provides excellent value to the City considering
service levels, staffing quality, reporting capacity,
and operational efficiency.

These proposals reflect clear justification of costs
and strong alignment with the RFP requirements.
____
100 TOTAL POINTS EARNED: ____
100
Parking Enforcement and Staffing Services
• City of East Palo Alto • November 17, 2025 •
Attachment 3: Proposal of Recommended Consultant
101
Parking Enforcement and Staffing Services
Transmittal Letter | City of East Palo Alto
Northern California
Regional Office
5901 Christie Ave
•Suite 202•
Emeryville, CA 94608
P: (510) 250-2052
F: (510) 345-3478
lazparking.com
1 A. TRANSMITTAL LETTER
November 17, 2025
Ms. Orly Amey
Assistant to the City Manager
City of East Palo Alto
2415 University Avenue
East Palo Alto, CA 94303
Subject: Proposal for Parking Enforcement and Staffing Services Dear Ms. Amey,
On behalf of LAZ Parking, I am pleased to submit our proposal to provide comprehensive parking enforcement staffing and services for the City of East Palo Alto. Our team is ready to support the City Council priority to expand parking enforcement capacity, strengthen daily operations, and improve compliance with the East Palo Alto Municipal Code while allowing Community Service Officers to refocus on broader public safety duties.

LAZ will deliver a dedicated, professional enforcement team that combines proactive patrols with timely response to community complaints across all neighborhoods, commercial corridors, schools, and community facilities.

Our plan emphasizes consistent enforcement of street sweeping restrictions, which are central to roadway cleanliness, stormwater management, and neighborhood satisfaction, as well as focused response to blocked driveways, abandoned vehicles, and long term on street storage concerns.

We understand that success in the first year will be measured by consistent coverage, improved parking compliance citywide, timely response to community concerns, fewer abandoned vehicles, and measurable reductions in chronic violations. Our approach includes clear beat structures, daily coverage expectations, and a two-hour response standard for complaint driven service, supported by robust reporting, citation data analytics, and regular performance reviews with the East Palo Alto Police Department.

LAZ will integrate seamlessly with the City’s existing TurboData citation platform and will provide all vehicles, equipment, uniforms, and communication tools required to perform the work. Our recruitment, screening, and training programs are aligned with EPAPD standards, including thorough background checks and emphasis on customer service. We will field a team that reflects the community, treats residents with respect, and supports the City’s commitment to safety, equity, and accountability.
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Transmittal Letter | City of East Palo Alto
Northern California
Regional Office
5901 Christie Ave
•Suite 202•
Emeryville, CA 94608
P: (510) 250-2052
F: (510) 345-3478
lazparking.com
2 To support clear communication, LAZ proposes the following points of contact for the City:

Primary contact:

MUHAMMAD MANSOOR PTMP
Vice President Municipal Operations
949 South Coast Drive Suite 515
Costa Mesa CA 92626
Mobile 714 290 4854
Email [email protected]
Secondary contact:

CINDY HEFNER
Regional VP, Northern California
5901 Christie Ave. Ste 202
Emeryville, CA 94608
O: (510) 250-2052
Email: [email protected]
Both contacts are authorized to negotiate on behalf of LAZ Parking and to bind the company in contractual matters with the City. Except as may be disclosed in our full proposal, no officer or employee of LAZ Parking has any financial or other interest in the City of East Palo Alto.

We appreciate the opportunity to be considered as your parking enforcement partner and look forward to the possibility of working with the City of East Palo Alto and the East Palo Alto Police Department to deliver a reliable, responsive, and community focused parking program.

Sincerely,

TABLE OF CONTENTS
City of East Palo Alto
Parking Enforcement and Staffing Services
A. Transmittal Letter........................................................................................................................................ 1 Table of Contents ................................................................................................................................................ 3 Executive Summary............................................................................................................................................. 4 B. description of proposer ................................................................................................................................... 6 About LAZ Parking ...........................................................................................................................................................................6 Nationally Recognized .....................................................................................................................................................................7 C. Proposer’s team.............................................................................................................................................. 8 D. Proposed approach & Methodology............................................................................................................... 10 Service Delivery Approach .............................................................................................................................................................10 Enforcement Methodology ............................................................................................................................................................14 E. Qualifications of the Firm .............................................................................................................................. 20 Government Sector Experience .....................................................................................................................................................21 Unparalleled Parking Enforcement Experience.............................................................................................................................22 F. Exceptions to the rfp...................................................................................................................................... 24 G. Project cost, fees and charges ...................................................................................................................... 25 H. References.................................................................................................................................................... 28 I. Professional Services Agreement................................................................................................................... 30 J. Statements .................................................................................................................................................... 30 K. Insurance Requirements................................................................................................................................ 30 104
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Executive Summary | City of East Palo Alto 4

EXECUTIVE SUMMARY
• CITY PARTNERSHIP AND GOALS
The City of East Palo Alto seeks a long-term partner to expand parking enforcement capacity, improve daily coverage, and respond more effectively to community concerns while allowing Community Service Officers to refocus on broader public safety duties. LAZ Parking fully supports this priority and proposes a turnkey enforcement program that delivers consistent citywide service, improves compliance with the East Palo Alto Municipal Code and California Vehicle Code, and directly supports the City Council work plan for fiscal years 2025 to 2027.
• PROVEN MUNICIPAL PARKING ENFORCEMENT LEADER
LAZ brings decades of experience operating municipal parking programs for cities across California and the United States, with a specific focus on citizen centric and community focused enforcement. We currently manage similar programs for neighboring and peer cities including Palo Alto, San Mateo, San Bruno, South San Francisco, San Leandro, and Salinas, along with dozens of other public agencies statewide. Our teams understand the realities of high residential demand, limited off street supply, and intense competition for curb space in compact communities, and we design programs that improve quality of life rather than simply increasing citation volume. • CITYWIDE ENFORCEMENT COVERAGE THAT FITS LOCAL CONDITIONS The scope of this RFP is citywide and balances proactive patrols with complaint driven response. LAZ will provide dedicated Parking Enforcement Officers to patrol all 83 lane miles of streets in East Palo Alto, including residential neighborhoods, commercial corridors such as University Avenue and Bay Road, schools, parks, and industrial or mixed-use areas. Our program emphasizes consistent enforcement of street sweeping restrictions, which are central to roadway cleanliness, stormwater management, and neighborhood satisfaction, and targeted response to blocked driveways, illegal parking in red zones and near fire hydrants, sidewalk parking, and long-term vehicle storage. • COVERAGE, RESPONSE TIMES, AND SERVICE STANDARDS
LAZ will meet and exceed the service level expectations described in the RFP. Each enforcement beat will receive proactive patrol at least once per day under the baseline model, with the ability to provide extended evening, early morning, weekend, or full 24 by 7 coverage as needed. Complaint driven requests received through the East Palo Alto Police Department will be addressed within two hours, supported by clear intake, dispatch, and tracking protocols under a City monitored, vendor hosted, or hybrid model based on City preference. Our deployment plan is built to deliver visible, predictable coverage that residents and businesses can rely on.
• COMMUNITY FIRST, ENFORCEMENT SECOND
A citizen centric approach is at the core of LAZ operations. Our enforcement officers serve as community ambassadors who prioritize education, clear communication, and voluntary compliance, especially during the initial launch period. We train staff to de escalate conflict, explain regulations in plain language, and treat every interaction as a chance to build trust with residents, visitors, and business owners. This 105
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Executive Summary | City of East Palo Alto 5
approach aligns with the City goal to strengthen compliance, reduce chronic problem locations, and enhance the perception of fairness and consistency in parking enforcement. • STAFFING ALIGNED WITH EPAPD STANDARDS
LAZ will recruit, hire, and retain qualified personnel whose screening process mirrors East Palo Alto Police Department standards, including full background checks, psychological and medical exams, and Department of Justice and CLETS clearance. We will staff a local Parking Enforcement Supervisor who coordinates daily with EPAPD, uses City office space at 901 Weeks Street as directed, and ensures coverage within three hours of any staff absence. Our training program will meet and expand on the City expectation of approximately forty hours of initial instruction, covering the East Palo Alto Police Department Parking Enforcement Training Manual, East Palo Alto Municipal Code, California Vehicle Code, court procedures, safety, customer service, and the physical layout of the City, followed by ongoing refresher training each year.
• TECHNOLOGY THAT SUPPORTS ACCURACY AND TRANSPARENCY
The City has invested in TurboData Magic and nForcer handheld devices as the standard platform for citation issuance. LAZ has extensive experience with TurboData technology and enforcement platform as we collaborate with TurboData on several CA based enforcement programs including San Mateo, San Bruno, South SF, Newport Beach and Malibu to name a few. LAZwill integrate directly with this existing system and will provide and maintain all required electronic citation equipment, radios, computers, and communications tools, while capturing digital photographic evidence to support accuracy and due process. We will supplement this foundation with GPS enabled patrol tracking, robust citation analytics, and optional Automated License Plate Recognition where appropriate, with data security, access, and retention policies that align with City expectations. All enforcement data will be delivered to the City in an approved format at least quarterly and at contract close-out, ensuring full ownership and long-term access to records.
• MEASURING WHAT MATTERS FOR THE COMMUNITY
Performance accountability is built into LAZ operations. In line with the City definition of success for year one, LAZ will track and report on consistent enforcement coverage across all beats, improvements in overall parking compliance, two hour response to resident complaints, reductions in abandoned vehicles and long term storage, and measurable declines in chronic violations. We will provide clear monthly and quarterly reports to EPAPD that summarize patrol activity, citation volume and type, complaint intake and resolution, and key trends. These reports will support joint problem solving with City staff and provide the transparency expected by the City Council and community. • FLEXIBLE MODEL READY FOR FUTURE GROWTH
Finally, LAZ understands that East Palo Alto is not seeking a generic enforcement vendor but a partner who will stand up a modern, community responsive parking program that can scale over time. Our proposed model is flexible enough to support baseline weekday operations within the City budget, expand to enhanced and 24 by 7 coverage if needed, and incorporate additional services such as a future Residential Parking Permit Program without disruption. With our deep municipal experience, strong regional presence, and proven record in neighboring cities, LAZ is uniquely positioned to help East Palo Alto deliver a safer, cleaner, and more livable curb environment for residents and businesses alike. 106
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B. description of proposer | C
B. DESCRIPTION OF PROPOSER
About LAZ Parking
Over Four Decades of Experience
LAZ Parking was founded in 1981 and has been at the forefront of the parking industry ever since, constantly innovating and adapting to the dynamic needs of our customers. Although we employ over 15,000 parking professionals in 42 states, each of our operations is managed locally. With over three decades of municipal parking experience, our local Bay Area based team will be responsible for providing citywide parking enforcement services. This team is already integrated, experienced in managing similar programs and ready to serve you.
• The largest privately held parking company in
the USA with a strong presence throughout
California
• Recently awarded multiple municipal contracts
in the Bay Area adding resources and support.
• Unique municipal parking experience, managing
more than 550,000 parking spaces for over 150
government agencies, cities and counties.
• Local and regional leaders dedicated to your
success, many with decades of parking
experience including hands on experience with
similar enforcement programs in the Bay Area.
• Dedicated Government Services support team for future program enhancements, effective research, rapid technology implementation and continuous municipal support.

At the core of LAZ Parking’s business model is a commitment to its employees, customers, and the communities it serves. LAZ's unique culture fosters engagement, accountability, and continuous improvement, driving consistently high performance. Additionally, the company places an emphasis on environmental sustainability, diversity, and social responsibility, ensuring its impact extends beyond business operations.

LAZ Parking’s ongoing growth, success, and
commitment to serving its clients stem from its
dedication to living its mission. The company’s
independence; a defining advantage among large
operators in the mobility industry empowers LAZ to
stay true to its principles and focus on building longterm, mutually beneficial relationships.

Today, LAZ operates over 4,000 locations and
manages 1.6 million parking spaces in 538 cities
across 42 states. By adhering to its founding
principles while embracing technological innovation
and corporate responsibility, LAZ continues to set the standard in the mobility industry. 107
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B. description of proposer | City of East Palo Alto 7
Nationally Recognized
IPMI Accredited Parking Organization with Distinction
LAZ Parking earned the Accredited Parking Organization (APO) with Distinction status in March 2024, recognizing the company’s excellence in financial and operational accountability, customer care, employee training, sustainability, and technological innovation. This certification, granted for three years, establishes LAZ as a leader in the parking and mobility industry.

CAPP Certification Program
LAZ Parking promotes the Certified Administrators of Public Parking (CAPP) program, enhancing the expertise of its leadership team. Many of LAZ’s managers have earned or are working toward CAPP or CPP certifications, demonstrating a commitment to excellence in the parking industry.

Environmental, Social, & Governance (ESG)
LAZ Parking launched an ESG Division in 2022, aligning with its mission to create opportunities for employees and value for clients. The division focuses on social awareness, wellness, diversity, and sustainable business practices. LAZ collaborates with Quinn+Partners to implement ESG frameworks and achieve Net Zero by 2036. The company’s environmental goals include advancing electrification, embracing digitization, and supporting responsible suppliers.

Diversity, Equity, and Inclusion
DEI is a central component of LAZ’s ESG strategy. The company is focused on fostering an inclusive environment through diverse policies, performance monitoring, and accountability. LAZ supports small, minorityowned, and women-owned businesses through its Supplier Diversity and Inclusion Plan, promoting equity both within and outside the organization.

LAZ Charitable Foundation
The LAZ Charitable Foundation uplifts underserved
communities by supporting housing, education, food
security, mental health, and career development. Its
mission, “Elevating Humanity,” emphasizes
empowering individuals, promoting social justice,
and creating opportunities for everyone to thrive.

Deeply rooted in our DNA, LAZ seeks opportunities to
get involved in the communities we serve and are
particularly proud of our partnership with Special
Olympics Southern California, for whom we host an
annual charitable golf tournament and participate in
the annual Plane Pull at Long Beach Airport.
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C. Proposer’s team | City of East Palo Alto 8
C. PROPOSER’S TEAM
LAZ Parking maintains a dedicated, experienced team fully assigned to the City’s program. Our staffing model ensures consistent citywide coverage, balanced workloads, and clear accountability through direct on-site supervision and strong communication with City staff.

Local Management Team
Anthony Hamilton, Director of Operations
Anthony brings more than 12 years of progressive experience in parking operations and municipal enforcement management. Beginning his career as a parking cashier, his strong work ethic and leadership have propelled him into regional management, where he now oversees multiple LAZ Parking operations across Northern California, including enforcement programs throughout the Peninsula and South Bay. Anthony provides ongoing regional operational support to the enforcement programs in Northern CA, ensuring consistency, efficiency, and adherence to City performance standards. His experience spans municipal enforcement, commercial parking, special events, hospitals, luxury hotels, and large mixed-use developments. Known for his ability to manage complex, high-volume operations with professionalism and precision, Anthony excels in optimizing service delivery, strengthening client relationships, and implementing strategic initiatives that drive operational success across LAZ’s Northern California portfolio.

Steve Mooney PTMP, Regional General Manager
Steve Mooney joined LAZ Parking’s Northern California management team in 2021, bringing over 17 years of experience in the transportation and hospitality industries. His background includes commercial parking operations, municipal on-street enforcement, stadium and special event parking, and luxury hotel valet management. Steve began his career with The Ritz-Carlton Hotel Company, where his leadership and commitment to service excellence led to multiple management roles. Since transitioning to the parking and transportation sector in 2013, Steve has built a strong reputation for developing high-performing teams, strengthening client relationships, and driving operational efficiency across diverse portfolios. Steve continues to provide strategic and operational support for LAZ’s municipal and commercial programs throughout Northern California, including ongoing oversight assistance for all Bay Area enforcement programs.

Cindy Hefner, Regional Vice President
Cindy joined LAZ Parking in 2014 and brings over 18 years of parking industry experience and a proven record of operational excellence and leadership. As Regional Vice President, she provides strategic direction and operational support to ensure contract performance and client satisfaction in the region. Her expertise spans automated parking systems, enforcement operations, valet, and self-park management. Cindy’s focus on efficiency, team development, and service quality has driven consistent growth and client retention throughout her career. She plays an active role in supporting all enforcement programs in Northern California, working closely with the Contract Managers to sustain operational excellence and ensure alignment with the City’s goals. 109
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C. Proposer’s team | City of East Palo Alto 9
Municipal Parking Experts
Carrie Ann Verge, Director of Finance & Compliance
Carrie Ann Verge joined LAZ Parking in 2021 as part of the acquisition of Serco Parking Services. In her role as Director of Finance, she plays a vital role in ensuring the financial oversight and compliance of our national municipal portfolio. With over two decades of experience in the Transportation Industry, Carrie Ann has a strong background in supporting and managing government, state, and local contracts. She has a proven track record in developing price-towin strategies, conducting P&L forecasting and analysis, ensuring contract compliance, and overseeing internal audits. Carrie Ann holds a Bachelor of Science degree from Middle Tennessee State University (MTSU). Her expertise and dedication make her an invaluable asset to our team, contributing to our continued success.

Peter Cho PTMP, Senior Operations Manager
During his 24 years of parking management experience, Peter has been instrumental in providing measured leadership and guidance to his operational team by implementing proven systems to achieve optimal efficiency. Peter has implemented multiple municipal programs including first-time outsourced enforcement programs. He has worked closely with clients to develop policies and procedures that provide the operations with a consistent level of service. Peter has led the transition of several enforcement programs, most notably, Santa Ana, Newport Beach, San Marcos, San Leandro and San Mateo. His local knowledge and in-depth experience working in similar environments makes him a valuable resource to the City. Peter will serve in the dual role of a Transition Manager and then as the Operations Resource Manager for this program.

Muhammad Mansoor PTMP, VP - Municipal Operations
In his 22-year parking career, Muhammad has led the implementation of multiple parking enforcement programs throughout CA. He started his parking career with Central Parking System. While at Central Parking, he was responsible for the management of multiple municipal parking management contracts including Newport Beach, Santa Ana, Long Beach, Anaheim, Carson, and Riverside. Since joining LAZ, Muhammad has spearheaded transitions of 8 new CA based contracts in the past five years, namely, Inglewood, Palo Alto, Salinas, Santa Ana, Manhattan Beach, San Leandro, San Marcos, and San Mateo. As a subject matter expert across a broad range of parking programs, Muhammad is often called on to assess operational efficiencies and the application of new technologies. Muhammad will provide regional project oversight required to ensure City of East Palo Alto.needs are met throughout the life of the contract. Muhammad has access to all LAZ’s parking contracts, bringing best practices and lessons learned to the City of East Palo Alto and to the Parking Enforcement and Staffing Services program.

Robert Maroney PTMP, Executive VP - Government Services Rob Maroney joined LAZ Parking in 2015 as the Vice President of Government Services.

Rob is responsible for overseeing and supporting our rapidly expanding Government Services market, which includes municipal agencies and public private partnerships. With over 20 years of experience, Rob brings extensive experience in government operations, management, and consulting. He started his career in municipal government, and during his 12+ year career with Norfolk, VA, he served as the Director of Parking. Rob has access to all municipal contracts currently managed by LAZ and will bring his expertise to the City of East Palo Altoenforcement program, if LAZ is awarded this contract.
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D. Proposed approach & Methodology | City of East Palo Alto 10 D. PROPOSED APPROACH & METHODOLOGY
LAZ Parking understands that East Palo Alto is seeking a partner who can deliver consistent daily enforcement, timely response to neighborhood concerns, and a visible presence that improves compliance and quality of life. Our approach combines structured patrol coverage, clear complaint handling procedures, strong supervision, and proven technology used in neighboring cities such as Palo Alto, San Mateo, San Bruno, South San Francisco, San Leandro, and Salinas. We will operate as an extension of the East Palo Alto Police Department, with a citizen focused enforcement style that emphasizes education, fairness, and respect in every interaction.

Service Delivery Approach
LAZ will deliver a structured, community focused parking enforcement program that supports East Palo Alto’s goals for cleaner streets, responsive service, and improved compliance. Our approach focuses on proactive daily patrols, consistent street sweeping enforcement, timely response to neighborhood concerns, and tight coordination with the East Palo Alto Police Department.

Our service model rests on five pillars: continuity for the community, professionalism in every interaction, accountability for results, transparency in data, and adaptability as the program evolves.

Task 1 Program launch and transition management
Planned start up
LAZ will implement a detailed transition plan that moves from contract award to full deployment with minimal disruption. We will coordinate closely with EPAPD to confirm service levels, beats, complaint processes, and reporting needs.

Beat and route design
Within the first thirty days, LAZ will review existing patrol patterns, street sweeping schedules, school locations, commercial corridors, and known hot spots. We will design beat maps and patrol routes that ensure daily coverage of all program areas, including residential neighborhoods, University Avenue, Bay Road, parks, and industrial or mixed use areas.

Integration with Turbo Data Systems
LAZ will work directly with Turbo Data Systems to confirm device configuration, violation tables, and data flows so that citation issuance, uploads, and reporting are fully aligned with City expectations before full launch.

Kickoff and calibration
We will hold an operational kickoff meeting with City and EPAPD staff to confirm priorities, communication protocols, complaint handling, and performance benchmarks, including the two hour response standard for service requests.

Task 2 Daily parking enforcement operations
Coverage and schedules
LAZ will deploy Parking Enforcement Officers during the standard weekday hours defined in the RFP, with the ability to support extended hours and weekend coverage as directed by the City. Patrol plans will ensure that every beat in the City receives proactive coverage each day. 111
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D. Proposed approach & Methodology | City of East Palo Alto 11 Proactive enforcement focus
Officers will patrol all program areas to enforce the East Palo Alto Municipal Code and California Vehicle Code. This includes enforcement of street sweeping regulations, time restricted zones, permanent and temporary restrictions, accessible spaces, blocked driveways, commercial parking rules, and oversized vehicle restrictions.

Complaint driven response
In coordination with EPAPD, LAZ will respond to complaint-based requests for service, such as blocked driveways, red zones, and fire hydrants. We will meet the City expectation that these requests receive a response within two hours, with documented arrival time and outcome.

Supervisor oversight
Field supervisor will review patrol coverage, ride along with officers, and audit activity logs and citation samples. This oversight maintains consistency across beats and ensures that officers apply regulations fairly and explain expectations clearly to the public.

Task 3 Personnel recruitment, training, and management
Local, qualified team
LAZ will recruit and hire a dedicated Parking
Enforcement Supervisor and officers whose
qualifications meet or exceed EPAPD standards.

Screening will include background checks, reference
checks, and any psychological and medical
evaluations and clearances required by the City.

Comprehensive training
Every officer will complete a structured training program that covers the East Palo Alto Police Department Parking Enforcement Training Manual, East Palo Alto Municipal Code, California Vehicle Code, citation issuance procedures, safety, court
processes, customer service, de escalation, and the
geography of the City.

Ambassador style enforcement
LAZ applies an ambassador philosophy in municipal
enforcement programs across California. Officers
act as visible representatives of the City. They
provide directions, answer questions, and explain
regulations in plain language. The goal is to increase
voluntary compliance and reduce repeat violations,
not simply issue more citations.

Ongoing development and performance
Officers will receive periodic refresher training on
legal updates, policy changes, de escalation tools, and safe driving. Supervisors will use a structured performance review process that looks at coverage efficiency, accuracy of citation issuance, complaint handling, and quality of customer interactions.
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D. Proposed approach & Methodology | City of East Palo Alto 12 Task 4 Vehicles, uniforms, and enforcement technology
Eco friendly enforcement fleet
LAZ will furnish a dedicated fleet of brand
new vehicles for the East Palo Alto program.

These vehicles reduce emissions, support the
City’s focus on sustainability, and present a
professional image in every neighborhood. Each vehicle will be clearly marked with City approved graphics and LAZ branding, equipped with high visibility safety lighting, and maintained on a preventive schedule to maximize uptime.

GPS and telematics powered by Samsara
Every enforcement vehicle will be equipped with GPS and full telematics using the Samsara platform. This allows LAZ and the City to view patrol coverage by beat and time of day, verify adherence to deployment plans, review incidents, and link patrol activity to enforcement outcomes. Telemetry also supports coaching on safe driving and efficient routing.

Partnership with Turbo Data Systems
LAZ will provide the needed enforcement technology in direct partnership with Turbo Data Systems, the City’s citation processing vendor. Officers will issue citations electronically using City approved Turbo Data handheld devices, with the ability to issue handwritten citations as a backup. Devices will be configured with East Palo Alto specific violation codes, fee schedules, and business rules, and will capture digital photographs and location data to document each violation. LAZ will also provide printers, chargers and all required accessories.

Uniforms
LAZ will provide professional ambassador style uniforms that project an approachable, community focused presence. Uniforms will be clearly distinct from East Palo Alto Police Department uniforms in color, style, and markings so officers are not mistaken for sworn police personnel. All uniform designs, logos, and branding will be submitted to the City for review and approval prior to production and field deployment.

Task 5 Quality assurance, reporting, and
coordination with EPAPD
Daily data availability
LAZ will ensure that citation data uploads to Turbo Data on a daily basis so that EPAPD can obtain current activity through Turbo Data reporting tools, consistent with the City’s expectations.

Activity and performance reporting
We will provide regular operational reports that summarize patrol hours by beat, citations by type, complaint calls received and resolved, abandoned vehicle follow up, and street sweeping enforcement activity. Monthly and quarterly reports will track response times, coverage levels, and trends in chronic problem locations.
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D. Proposed approach & Methodology | City of East Palo Alto 13 Joint review and problem solving
LAZ will meet routinely with EPAPD leadership
to review results, discuss community feedback,
refine deployment, and adjust priorities. We will
also support City staff with clear data and
simple visuals for Council updates or
community presentations on the parking
program.

Quality control checks
Supervisors and regional management will
conduct audits of citation samples,
photographs, patrol logs, and complaint
records. Findings feed back into coaching and
training so that the program keeps improving over the life of the contract.

Task 6 Community engagement and
customer service
Citizen centered enforcement
LAZ officers will act as community ambassadors. They explain the reasons behind regulations, provide advance warnings during early stages of new or adjusted enforcement, and treat every contact as a chance to build trust.

Public education and outreach support
LAZ will support City led education efforts on street sweeping schedules, new enforcement areas, and any future residential permit or special programs. This may include flyers, door hangers in high impact areas, and a consistent message from officers in the field.

Complaint logging and resolution
All complaints related to officer conduct or citations issued will be logged, reviewed, and resolved using a documented process. Outcomes will be summarized in regular reports to EPAPD, closing the feedback loop and reinforcing
accountability.

Through this approach, LAZ delivers a complete, technology enabled, eco-friendly enforcement program that meets East Palo Alto’s needs for proactive patrols, reliable complaint response, strong street sweeping enforcement, and visible support for neighborhood quality of life.
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D. Proposed approach & Methodology | City of East Palo Alto 14 Enforcement Methodology

PROACTIVE PATROL COVERAGE AND DAILY BEAT ENFORCEMENT
LAZ will design and implement a beat-based deployment plan that ensures every area of the City receives proactive patrol at least once per day under the baseline service level.

We will:

1. Divide the City into logical enforcement beats that align with the City’s existing deployment map, taking into account residential neighborhoods, commercial corridors such as University Avenue and Bay Road, schools, parks, and industrial or mixed-use areas.

2. Create written deployment plans that specify the sequence and approximate timeframes for each beat, including peak demand periods such as early morning street sweeping times and school arrival and dismissal windows.

3. Assign Parking Enforcement Officers to specific beats for defined time blocks, which builds familiarity with neighborhood conditions, recurring issues, and local stakeholders.

4. Use GPS enabled patrol tracking and daily activity reports to confirm that each beat has been covered as scheduled and to adjust routes based on observed violation patterns and community feedback.

This structure delivers predictable, visible enforcement throughout the City, with flexibility to add targeted emphasis patrols for emerging hot spots or special projects.

COMPLAINT INTAKE, DOCUMENTATION, AND TWO-HOUR RESPONSE
LAZ will support a simple and reliable pathway for community members to report parking concerns and will commit to responding to complaint driven service requests within two hours.

Our complaint handling process will:

1. Use the East Palo Alto Police Department as the primary intake channel for complaints, using the City’s existing non-emergency phone line and any online or email tools the City designates.

2. Log each complaint in a shared tracking system that records the caller information when available, location, type of issue, time received, and any special notes such as mobility needs or repeated violations.

3. Dispatch the closest available Parking Enforcement Officer by radio or secure mobile device and provide clear location details, including cross streets and landmarks.

4. Require the officer to document arrival time, actions taken, and outcome, including citation issuance, warning, vehicle relocation, or confirmation that no violation was present.

5. Close the request in the system with final disposition and attach citation numbers or photographs when applicable.

Supervisors will review open requests throughout each shift to confirm that all service calls are addressed within the two-hour response window. Patterns in complaint locations will be used to adjust patrol plans and to support targeted education and outreach. 115
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D. Proposed approach & Methodology | City of East Palo Alto 15

STREET SWEEPING ENFORCEMENT AND NEIGHBORHOOD OUTCOMES
Street sweeping enforcement is a core focus of our approach because it directly affects roadway cleanliness, stormwater management, and neighborhood satisfaction.

To maintain consistent enforcement of street sweeping regulations, LAZ will:

1. Build street sweeping routes and schedules into our beat deployment plans so that Parking Enforcement Officers are in place ahead of sweeping times.

2. Prioritize enforcement of posted street sweeping zones during the critical time window, using license plate scans and visual checks to identify violators.

3. Capture photographic evidence for each street sweeping citation to support accuracy and to help residents understand the basis for enforcement.

4. Work with City staff to monitor complaint trends, flooding or debris issues, and feedback from the Public Works team, adjusting enforcement emphasis where sweeping outcomes are not meeting expectations.

5. For the first months of the contract, pair enforcement with targeted education for residents in areas with frequent violations, including door hangers, informational flyers, and clear explanations during in person encounters.

This combination of predictable enforcement and focused outreach supports cleaner streets, improved stormwater performance, and better acceptance of the program.

STAFFING LEVELS, BEAT STRUCTURES, AND VISIBLE DEPLOYMENT LAZ will implement staffing levels that match the City’s desired baseline coverage and provide a framework for future expansion to extended hours or seven day service if requested.

Key elements include:

1. A dedicated onsite Parking Enforcement Supervisor who reports to LAZ management and coordinates daily with EPAPD leadership.

2. A core team of Parking Enforcement Officers sized to provide daily patrol of all beats, coverage of key street sweeping windows, and capacity to respond to complaint driven calls within two hours.

3. Fixed shift schedules that cover the primary enforcement hours defined by the City, with optional staggered start times to provide early morning and evening presence as needed.

4. Clear written post orders for each beat and shift, specifying required patrol routes, key locations, priority corridors, and special conditions such as schools or construction zones.

Officers will patrol primarily in marked enforcement vehicles with high visibility decals and safety lighting, supplemented by foot patrol in high density or sensitive areas. The visible presence of trained, uniformed staff reinforces compliance and reassures residents that the City is actively managing curb space.
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D. Proposed approach & Methodology | City of East Palo Alto 16

TECHNOLOGY ENABLED ENFORCEMENT, ACCURACY, AND ACCOUNTABILITY LAZ will leverage and enhance the City’s existing technology platform to deliver accurate and accountable enforcement.

Our approach includes:

1. Full integration with Turbodata Magic and the City’s existing handheld citation devices, including configuration of citation templates, violation codes, and business rules consistent with the East Palo Alto Municipal Code and California Vehicle Code.

2. Use of GPS enabled patrol tracking for all enforcement vehicles and handheld devices, allowing supervisors and the City to verify coverage by beat and time of day.

3. Optional deployment of Automated License Plate Recognition units in selected zones, such as high turnover commercial corridors or around schools, to quickly identify scofflaw vehicles, time limit violations, and potential abandoned vehicles.

4. Standard capture of digital photographs and location data for every citation to document the violation, support adjudication, and increase public confidence in the fairness of enforcement.

5. Secure storage and role-based access controls for all enforcement data, with clear retention schedules that align with City policy and legal requirements.

All technology components will be supported by LAZ, including maintenance, replacement, and training, so that EPAPD can focus on oversight and policy.

PERFORMANCE MONITORING, REPORTING, AND COMMUNICATION WITH EPAPD LAZ will establish a structured performance management framework backed by regular communication with the East Palo Alto Police Department.

We will:

1. Confirm during implementation that all citations issued by LAZ staff upload to Turbodata on at least a daily basis, so that EPAPD can obtain daily activity reports directly from Turbodata reporting tools.

2. Provide supplemental daily or weekly activity summaries to EPAPD in an agreed format, including patrol hours by beat, number and type of citations issued, complaint calls received and resolved, abandoned vehicle follow up, and notable incidents.

3. Produce formal monthly and quarterly performance reports that track key indicators, such as beat coverage, compliance trends, response times, and chronic problem locations, and that highlight recommendations for targeted enforcement or education.

4. Hold regular standing meetings with EPAPD leadership to review results, discuss community feedback, and adjust deployment or priorities as conditions change.

5. Support City presentations to the Council or community groups by providing clear data visuals and explanations of enforcement outcomes.

This structure gives the City real time insight into operations while maintaining clear accountability for results.
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D. Proposed approach & Methodology | City of East Palo Alto 17

IMPLEMENTATION SCHEDULE, RAMP UP, AND TRANSITION PLAN
LAZ will implement the program through a structured transition plan that moves from planning to full deployment while minimizing disruption. A typical schedule is as follows, and can be adjusted to align with City timelines:

WEEK 1 TO 2

1. Contract execution and formal kickoff meeting with EPAPD and City staff.

2. Confirmation of goals, service level expectations, and reporting requirements.

3. Detailed review of current enforcement practices, Turbodata configuration, and existing beat maps.

WEEK 3 TO 4

1. Recruitment and conditional hiring of Parking Enforcement Officers and Supervisor, including initial screening.

2. Ordering and configuration of uniforms, vehicles, handheld devices, radios, and GPS tracking tools.

3. Drafting of post orders, deployment plans, and complaint handling protocols.

WEEK 5 TO 6

1. Completion of full background checks, psychological and medical exams, and required clearances consistent with EPAPD standards.

2. Delivery of approximately forty hours of initial training covering the East Palo Alto Police Department Parking Enforcement Training Manual, East Palo Alto Municipal Code, California Vehicle Code, court procedures, safety, customer service, and city geography.

3. Ride alongs and field coaching with experienced LAZ municipal enforcement staff from nearby programs to reinforce best practices.

WEEK 7 TO 8

1. Soft launch of enforcement with limited hours and enhanced supervisor presence, focused on testing routes, technology, and complaint handling.

2. Final configuration of Turbodata reporting, GPS dashboards, and performance metrics.

3. Full deployment to the agreed service level with daily proactive enforcement across all beats and two hour response to complaint driven calls.

Throughout the transition, LAZ will coordinate closely with EPAPD on messaging to the community, especially around street sweeping, school zones, and any known hot spot areas. 118
Parking Enforcement and Staffing Services
D. Proposed approach & Methodology | City of East Palo Alto 18

OPTIONAL ENHANCEMENTS AND INNOVATIONS
In addition to the core scope, LAZ can provide several optional enhancements to further improve efficiency, responsiveness, and community confidence. These can be priced as separate line items, such as:

1. A simple online or mobile friendly complaint
submission form branded for the City, feeding
directly into the complaint tracking system and
Turbodata or a compatible platform.

2. Enhanced ALPR deployment for targeted corridors,
including analytics to identify repeat offenders,
time limit abuse, and vehicles with multiple unpaid
citations.

3. Community ambassador shifts during the first
months of the program, focused on education,
warnings, and distribution of informational
materials prior to full enforcement.

4. Periodic joint “parking checkup” days with City staff where LAZ and EPAPD walk key corridors, engage with businesses and residents, and adjust signage or enforcement practices based on feedback.

This approach and methodology gives East Palo Alto a structured, data informed, and community focused parking enforcement program that can meet current needs and scale to support future initiatives such as a residential permit program or extended hour enforcement. 119
Parking Enforcement and Staffing Services
D. Proposed approach & Methodology | City of East Palo Alto 19

IMPLEMENTATION PLAN AT A GLANCE
Phase Timeframe Key activities
Phase 1
Planning and
kickoff
Weeks 1 to 2
Contract execution and kickoff meeting with City and East Palo Alto Police Department; confirm goals, service level expectations, KPIs, and reporting needs; review current enforcement practices, Turbodata configuration, existing beat maps, and street sweeping schedules; define communication channels, points of contact, and escalation paths
Phase 2
Recruitment and
equipment
Weeks 3 to 4
Recruit and conditionally hire Parking Enforcement Supervisor and Officers; begin screening and reference checks; order and outfit enforcement vehicles; procure uniforms, handheld citation devices, radios, and GPS tracking tools; draft post orders, beat deployment plans, and complaint intake and dispatch procedures
Phase 3
Background
checks and
training
Weeks 5 to 6
Complete background checks, psychological and medical exams, and required clearances consistent with EPAPD standards; deliver approximately forty hours of initial training on EPAPD Parking Enforcement Training Manual, East Palo Alto Municipal Code, California Vehicle Code, court procedures, safety, customer service, and city geography; configure Turbodata profiles, violation tables, business rules, and reporting templates; conduct ride alongs and field coaching with experienced LAZ municipal enforcement staff Phase 4
Soft launch and
system
validation
Weeks 7 to 8
Begin soft launch with limited enforcement hours and enhanced supervisor presence; test patrol routes, beat coverage, complaint intake and dispatch workflow, Turbodata uploads, GPS tracking, and daily reporting; fine tune beat structures and shift schedules based on field results and community feedback; coordinate public messaging for priority areas such as street sweeping routes, school zones, and known hot spots
Phase 5
Full deployment
and optimization
Week 9 and
ongoing
Move to full service level with daily proactive patrol on all beats and two hour response to complaint driven calls; monitor coverage, response times, citation trends, and street sweeping outcomes; provide regular activity and performance reports to EPAPD; refine deployment and staffing based on data and neighborhood input; identify, propose, and implement optional enhancements such as targeted ALPR deployment, ambassador style education days, and online complaint submission tools
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E. Qualifications of the Firm | City of East Palo Alto 20 E. QUALIFICATIONS OF THE FIRM
As a full-service parking management company with more
than four decades of municipal experience, LAZ Parking
fully understands the transformative impact of a wellmanaged parking program on community accessibility, quality of life, and economic vitality. Since 2016, LAZ has proudly partnered with the City of Salinas, delivering
professional, consistent, and customer-focused parking
enforcement services that have strengthened compliance, supported Public Works initiatives, and improved
neighborhood livability. Across California, LAZ has earned a reputation as the trusted partner of choice for dozens of cities nationwide; each partnership reflecting our ability to adapt to local needs, maintain operational excellence, and deliver measurable results.

Our Government Services Division is recognized nationally for its unparalleled expertise in municipal parking operations. We currently manage more than 550,000 parking spaces and issue over 1.5 million citations for public agencies across the United States, providing enforcement, permit management, and technology integration services for municipalities, transit authorities, and state and federal agencies. Our government portfolio includes high-demand downtowns, residential permit zones, and citywide enforcement programs comparable in scale and
complexity to Salinas.

Our comprehensive approach combines data-driven
enforcement, advanced technology, and community
engagement to promote compliance and improve the
parking experience for residents, businesses, and visitors.

LAZ’s services encompass full lifecycle parking
management; from enforcement and citation issuance to
permit administration and mobile payment integration
supported by robust revenue integrity controls, transparent reporting, and superior customer service. We bring the
resources of a national operator with the accountability and responsiveness of a local partner, ensuring each program operates efficiently, cost-effectively, and in full compliance with City policies and state laws.

With extensive experience managing long-term municipal
contracts, LAZ has developed industry-leading systems for performance measurement, staff training, and service quality assurance. Our focus on sustainability, safety, and operational integrity ensures that every dollar entrusted to us delivers visible community benefit. For the City of East Palo Alto, LAZ offers not only proven capability but also a deep, ongoing commitment to being a responsive, innovative, and reliable partner dedicated to enhancing the City’s parking enforcement program today and into the future. 121
Parking Enforcement and Staffing Services
E. Qualifications of the Firm | City of East Palo Alto 21 Government Sector Experience
Our experience, leadership and philosophy have made LAZ Parking one of the nation’s premier operators specializing in parking services for municipalities and government agencies. We have an unmatched track record operating municipal parking systems and currently manage more than 550,000 parking spaces for over 150 government agencies, cities and counties.

The following is provided as a sample of LAZ Parking’s public sector clients, including the approximate number of spaces for each:

California Partnerships
• City of Long Beach (10,300)
• Long Beach Municipal Airport (1,550)
• City of San Francisco On Street (28,800)
• City of Inglewood, (12,750)
• City of Stockton (6,145)
• City of Burbank (1,475)
• City of Malibu (1,950)
• City of Newport Beach (4,100)
• City of Glendale (3,008)
• City of Los Angeles / LADOT (38,000)
• City of West Hollywood (3,360)
• City of San Francisco Off Street (3,115)
• California State Parks (2,665)
• City of San Mateo (2,610)
• County of Alameda (2,500)
• City of Calabasas (1,100)
• LA Beaches & Harbors (10,000)
• LAX IT (1,500)
• City of San Bruno (1,820)
• City of San Leandro (1,450)
• City of San Marcos (1,200)
• City of South San Francisco (2,100)
• City of Santa Ana (2,500)
National Partnerships
• Washington Metro Area Transit Auth (59,000)
• City of Las Vegas (NV) (3,000)
• Volusia County, FL (2,100)
• City of Baton Rouge, LA (2,000)
• City of Coral Gables, FL (1,775)
• City of Baltimore, MD (1,440)
• City of South Miami, FL (1,400)
• City of Arvada, CO (1,100)
• Cobb County, GA (1,380)
• City of Chicago Meters System (36,000)
• Montgomery County, MD (21,500)
• NY City Housing Authority (20,000)
• NY Metro Transit Authority (16,600)
• City of Lincoln, NE (14,780)
• Rhode Island State Beaches (8,100)
• City of Kansas City, MO (6,600)
• City of Miami Beach, FL (6,000)
• City of New Rochelle, NY (5,868)
• City of Lowell, MA (5,566)
• Norwalk Parking Authority (4,233)
• City of Stamford, CT (3,400)
• Birmingham Jefferson Conv. Complex (2,700)
• City of Syracuse, NY (2,525)
• City of Westminster, CO (2,500)
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Parking Enforcement and Staffing Services
E. Qualifications of the Firm | City of East Palo Alto 22 Unparalleled Parking Enforcement Experience
LAZ Parking is a national leader in municipal parking enforcement with a dedicated Parking Enforcement Business Segment operating within our Government Services Division. Since 1988, we have delivered reliable, professional enforcement services to municipalities across the United States, issuing nearly 1.5 million citations each year while maintaining an industry-leading accuracy rate with fewer than three percent of citations dismissed. This level of performance reflects our commitment to precision, accountability, and service quality.

With more than four decades of experience supporting local governments, LAZ has successfully transitioned numerous enforcement programs from internally managed or police-led operations to efficient, transparent, and technology-enabled contracted services. These partnerships have allowed cities to strengthen compliance, reduce administrative costs, and improve community satisfaction through professionalized operations and clear communication with the public.

Today, LAZ manages more than 150 government contracts nationwide and maintains a record of 100 percent contract renewals, a reflection of our clients’ trust and the consistent results we deliver. Our expertise includes the design and operation of complex enforcement programs that require extensive coordination with city departments, law enforcement, and public works divisions to align with local objectives and maintain community confidence.

LAZ’s longstanding presence in California includes partnerships with cities such as Palo Alto, San Mateo, Salinas, San Bruno, South San Francisco, San Leandro in Northern CA and over a dozen cities in Southern California. These relationships demonstrate our ability to deliver high-performing programs in dynamic, high-density environments where parking enforcement directly supports mobility, safety, and quality of life.

Technology and innovation are central to LAZ’s enforcement success. We utilize License Plate Recognition (LPR) systems, electronic handheld citation devices, and fully integrated cloud-based citation management and enforcement systems that streamline operations and increase accuracy. All enforcement data flows into LAZ’s Business Intelligence (BI) platform, a unified reporting system that gives our municipal partners real-time insight into enforcement activity, citation trends, and compliance patterns. This allows cities like East Palo Alto to make informed, data-driven decisions and refine parking policies to better serve residents, visitors, and businesses.

LAZ brings a proven record of success, supported by technology integration, advanced training, and realtime operational oversight. Our enforcement programs utilize license plate recognition technology, cloudbased citation management systems, and data-driven reporting tools that provide full transparency and actionable insights. These capabilities will enable East Palo Alto to efficiently manage 24/7 enforcement operations, ensure compliance with municipal codes, and maintain the integrity of its street sweeping and general enforcement programs.

Above all, LAZ’s approach to enforcement is citizen centric and community focused. We emphasize professionalism, consistency, and respect in every interaction while upholding the City’s parking regulations and public safety goals. Our proven experience, dedicated personnel, and technology-driven solutions position LAZ Parking as the ideal partner to support the City of East Palo Alto in delivering a modern, efficient, and service-oriented parking enforcement program. 123
Parking Enforcement and Staffing Services
E. Qualifications of the Firm | City of East Palo Alto 23 The table below highlights a selection of municipalities where LAZ Parking provides parking enforcement and compliance management services. These programs represent a wide range of enforcement models, from street sweeping and general parking enforcement to citation processing, permit management, and technology integration. Each example reflects LAZ’s ability to adapt to the unique needs of our municipal partners and deliver efficient, transparent, and community-oriented enforcement operations consistent with the goals of the City of East Palo Alto. ANNUAL CITATIONS ISSUED OPERATIONS/MANAGEMENT PARKING ENFORCEMENT ELECTRONIC HANDHELDS

SMART TECHNOLOGY

LPR TECHNOLOGY

ENFORCE ALL MCS
& STATE CVC

PERMIT ENFORCEMENT

ON STREET ENFORCEMENT

OFF-STREET ENFORCEMENT

SURFACE LOTS

STREET SWEEPING ENFORCE

CUSTOMER PHONE SUPPORT

TOWING AND BOOTING

TRAFFIC DISPATCH SERVICES

TRAFFIC CONTROL SERVICES
California Municipal Enforcement Clients
City of West Hollywood 200,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ City of Inglewood 90,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
City of Santa Ana 45,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
CA State Parks 30,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
City of Salinas 20,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
City of Palo Alto 10,500 ✓ ✓ ✓ ✓ ✓ ✓ ✓
City of San Mateo 32,500 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Newport Beach 70,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
City of San Marcos 10,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
City of San Leandro 15,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓
City of Burbank 45,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
National Municipal Enforcement Clients
City of Chicago, IL 550,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Montgomery County,
MD 150,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
New York MTA 50,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
South Miami, FL 45,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Norwalk, CT 40,000 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
City of Arvada, CO 10,500 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
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Parking Enforcement and Staffing Services
F. Exceptions to the rfp | City of East Palo Alto 24
F. EXCEPTIONS TO THE RFP
LAZ Parking has carefully reviewed the City of East Palo Alto’s Request for Proposals for Parking Enforcement and Staffing Services.

LAZ Parking does not take exception to any portion of the RFP.

We agree to comply with all requirements, terms, and conditions as outlined in the RFP and its attachments and will perform the services requested in full accordance with the City’s specifications and objectives.
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G. Project cost, fees and charges | City of East Palo Alto 25 G. PROJECT COST, FEES AND CHARGES
LAZ Parking submits this pricing proposal in full compliance with Section G of the RFP and the City’s clarifications in the posted Q and A . All costs required to deliver parking enforcement services in East Palo Alto are fully bundled into the fixed monthly and annual fees shown below. No additional reimbursement will ever be requested for fuel, insurance, uniforms, handheld devices, ticket stock, telematics, maintenance, administrative overhead, or travel within the service area.

Our pricing is based on a clear and predictable fixed fee structure that aligns with the City’s need for transparency, comparability, and long-term cost stability. LAZ provides three scalable service levels that match the RFP’s Baseline, Enhanced, and Comprehensive Coverage models. Each option includes all labor, supervision, Toyota Corolla Hybrid enforcement vehicles equipped with GPS and full Samsara telematics, handheld enforcement technology integrated with Turbo Data Systems, uniforms including body cameras, and all required equipment.

SUMMARY OF SERVICE LEVEL OPTIONS
Service Level
Fixed
Monthly
Cost
Fixed
Annual
Cost
Annual
PEO
Hours
Vehicles Technology and Equipment
Included
Option 1
Baseline Service 17,474 209,684 3,840
2 Toyota
Eco-Friendly
units
Turbo Data handhelds, body
cameras, uniforms, fuel,
maintenance, insurance, GPS,
Samsara telematics
Option 2
Expanded
Coverage
25,135 301,616 5,760
3 Toyota
Eco-Friendly
units
Turbo Data handhelds, body
cameras, uniforms, fuel,
maintenance, insurance, GPS,
Samsara telematics
Option 3
Comprehensive
24 Hour Coverage
33,039 396,467 7,680
4 Toyota
Eco-Friendly
units
Turbo Data handhelds, body
cameras, uniforms, fuel,
maintenance, insurance, GPS,
Samsara telematics

STAFFING PLAN BY SERVICE LEVEL
Service Level Staffing Structure Coverage Approach
Option 1
Baseline
One Parking Enforcement Officer
per shift; regional Supervisor
oversight
Weekday coverage aligned with primary
enforcement hours and daily beat patrol
requirements
Option 2
Expanded
Coverage
Up to two Parking Enforcement
Officers per day + 1 Supervisor
Expanded weekday coverage with flexibility for
limited weekend enforcement as directed
Option 3
24 Hour
Coverage
Continuous PEO staffing for
around-the-clock enforcement + 1
Supervisor
Full 24-hour enforcement capability, supporting
proactive patrols and rapid response to overnight
issues and complaints
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G. Project cost, fees and charges | City of East Palo Alto 26

COST INCLUSIONS
Category Included in All Options
Vehicles Eco friendly brand new vehicles, fully marked, with fuel, maintenance, insurance, GPS, and Samsara telematics
Technology Turbo Data integrated handheld citation devices, ticket stock, chargers, mounts, and system configuration
Uniforms Full ambassador style uniforms including body cameras Operations All administrative overhead, supervision, complaints response, and patrol deployment Equipment Radios, safety gear, communications tools, and spare handheld devices Other
Costs Travel within service area, training, onboarding, and all incidental operating expenses

OPTIONAL SERVICES (AVAILABLE UPON CITY REQUEST)
Optional Service Staffing Plan Cost Basis
Residential Parking Permit Program
enforcement
Deployment based on number of zones and
hours requested
$44.40 per
hour
Special event or targeted enforcement Temporary PEO staffing, Supervisor oversight as required
$44.40 per
hour
Weekend only enforcement One or more PEOs depending on coverage desired
$44.40 per
hour

PROJECTED ANNUAL CITATION OUTPUT BY SERVICE LEVEL
Because LAZ will deploy dedicated, full-time enforcement personnel with proactive beat coverage, daily street sweeping enforcement, and a two-hour complaint response requirement, citation issuance is expected to increase proportionally to available enforcement hours.

To build the projection, three inputs are used:

1. Current annual citations issued with partial enforcement: approx. 12,359

2. Estimated annual CSO hours spent on enforcement: approx. 1,500 to 2,000 hours (based on one CSO per day shift providing partial enforcement and no dedicated enforcement hours)

3. Proposed LAZ annual enforcement hours by option:

Option 1: 3,840 hours
Option 2: 5,760 hours
Option 3: 7,680 hours

PRODUCTIVITY MULTIPLIER ASSUMPTION
Because CSOs were not dedicated to enforcement and often prioritized higher-level police duties, dedicated private-sector PEOs typically produce 20 to 35 percent more citations per hour when deployed consistently. The projection below uses a conservative 25 percent productivity uplift. 127
Parking Enforcement and Staffing Services
G. Project cost, fees and charges | City of East Palo Alto 27

PROJECTED ANNUAL CITATION ISSUANCE BY SERVICE LEVEL
Baseline Data Point
Estimated CSO enforcement hours: 1,800 per year
Actual citations issued FY24/25: 12,359
Citations per enforcement hour: approx. 6.9 citations per hour To avoid overstating projections, LAZ uses a reduced working benchmark of 5.5 to 6.5 citations per hour, depending on coverage level, factoring in resident interactions, complaint response, vehicle checks, and street sweeping timing.

Option 1 Baseline Service
3,840 annual PEO hours
Citation rate used: 5.5 citations per hour
Projected annual citations: approx. 21,100
Rationale:

Dedicated coverage more than doubles current enforcement hours, producing a sustainable increase in enforcement visibility and compliance.

Option 2 Expanded Coverage
5,760 annual PEO hours
Citation rate used: 6.0 citations per hour
Projected annual citations: approx. 34,500
Rationale:

The larger coverage window captures AM peaks, PM congestion, and consistent school-area and street sweeping enforcement, all of which historically generate higher violation counts.

Option 3 Comprehensive 24-Hour Coverage
7,680 annual PEO hours
Citation rate used: 6.5 citations per hour
Projected annual citations: approx. 49,900
Rationale:

Full coverage enables overnight enforcement, abandoned vehicle identification, chronic violator detection, and expanded complaint response, all of which materially increase citation volume and compliance.

SUMMARY TABLE
Service Level Annual Enforcement
Hours
Estimated Citations per
Hour
Projected Annual
Citations
Option 1 - Baseline 3,840 5.5 21,100
Option 2 - Expanded 5,760 6.0 34,500
Option 3 - 24 Hour 7,680 6.5 49,900
Under all three options, City should expect a meaningful increase in citation volume. This is driven by the transition from partial enforcement to dedicated, full-time PEO deployment, structured beat coverage, consistent street sweeping operations, and rapid response to resident complaints. These improvements will enhance compliance, reduce chronic violations, support street sweeping operations, and improve neighborhood satisfaction, aligning with the City’s Year 1 success expectations. 128
Parking Enforcement and Staffing Services
H. References | City of East Palo Alto 28
H. REFERENCES
LAZ Parking brings deep experience delivering municipal parking enforcement services throughout California, supporting cities with programs that emphasize community trust, consistent enforcement, data driven operations, and strong collaboration with local police departments. The following California agencies rely on LAZ for enforcement programs that mirror the scope, complexity, and community expectations of East Palo Alto. These references demonstrate LAZ’s proven record of performance, responsiveness, and partnership in diverse urban environments. 1 Name of Agency: City of South San Francisco/ South San Francisco Police Dept.

Street Address: 1 Chestnut Avenue, South San Francisco, Ca., 94080 Contract Value & Term $0.7M – Continuously serving since October 2024 Scope of Services Citywide parking enforcement services including all MCs and CVCs (Street Sweeping Enforcement, RPP, timed zones and posted signs).

Name of Person to Contact: Captain Ken Chetcuti, Operations Division Phone Number of Contact: 650.877.8920
Email Address of Contact: [email protected]
2 Name of Agency: City of Santa Ana / Santa Ana Police Department Street Address: 20 Civic Center Plaza, Santa Ana, CA 92701 Contract Value & Term $4.7M – Continuously serving since July 2018 Scope of Services Citywide parking enforcement services including all MCs and CVCs (Street Sweeping Enforcement, parking meters, RPP, alleys, blocked driveways, lawn parking, 24/7 operation with commercial street sweeping covered during graveyard).

Name of Person to Contact: Yolanda Bautista
Phone Number of Contact: 714-245-8225
Email Address of Contact: [email protected]
3 Name of Agency: City of Burbank / Burbank Police Department Street Address: 200 N. 3rd Street, Burbank, CA 91502
Contract Value & Term $6.5M – Continuously serving since April 2023 Scope of Services Citywide parking enforcement services including all MCs and CVCs (Street Sweeping Enforcement, RPP, timed zones and posted signs).

Name of Person to Contact: Lieutenant John Pfrommer
Phone Number of Contact: 818-238-3106
Email Address of Contact: [email protected]
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H. References | City of East Palo Alto 29
4 Name of Company/Agency: City of West Hollywood
Street Address: 8300 Santa Monica Blvd., West Hollywood, CA 90069 Contract Value & Term $14M – Continuously serving since July 2020 Scope of Services Turnkey Parking Enforcement Services 24 hours/day-365 days/year (all MCs & CVCs), Vehicle/Bike/Foot Patrol, Traffic Control, Dispatch Services, Front Counter Customer Service, Encroachment/Temp Permit Placement, Towing, Court Appearances. Street Sweeping Enforcement.

Name of Person to Contact: Vince Guarino
Phone Number of Contact: 323-848-6426
Email Address of Contact: [email protected]
5 Name of Company/Agency: City of San Mateo / San Mateo Police Department Street Address: 200 Franklin Parkway, San Mateo, CA 94403 Contract Value & Term $7.1M – Continuously serving since November 2019 Scope of Services Citywide parking enforcement service including all MCs and CVCs.

Street Sweeping & Citywide Parking Enforcement including parking meters, RPP, timed zones, and posted signs.

Name of Person to Contact: Sgt. Craig Collum
Phone Number of Contact: 650-522-7742
Email Address of Contact: [email protected]
6 Name of Company/Agency: City of Malibu
Street Address: 23825 Stuart Ranch Road | Malibu, CA 90265 Contract Value & Term $1.1M – Continuously serving since June 2024 Scope of Services Citywide parking enforcement service including all MCs and CVCs including timed zones, and posted signs.

Name of Person to Contact: Susan Duenas
Phone Number of Contact: (310) 456-2489 ext. 313
Email Address of Contact: [email protected]
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I. Professional Services Agreement | City of East Palo Alto 30 I. PROFESSIONAL SERVICES AGREEMENT
LAZ Parking has reviewed the City of East Palo Alto’s standard Contractor and Professional Services Agreement included as Attachment 5.

LAZ Parking does not request any modifications or exceptions to the Agreement and fully accepts the terms and conditions as written, subject only to minor modifications the City may make during finalization.

J. STATEMENTS
Financial, business, or other relationships
LAZ Parking has no financial, business, or other relationships with any company or firm that has an active or pending development application with the City of East Palo Alto.

Litigation, bankruptcy, or reorganization
Neither LAZ Parking nor any officer or employee with a proprietary interest in the company is presently or has been involved in litigation, bankruptcy, or reorganization related to the company.

Disqualification or removal from government projects
Neither LAZ Parking nor any officer or employee with a proprietary interest in the company has ever been disqualified, removed, or otherwise prevented from proposing on or completing a federal, State, or local government project due to a violation of law or safety regulation.

K. INSURANCE REQUIREMENTS
LAZ Parking acknowledges receipt of the City’s insurance requirements outlined in Exhibit C and affirms that LAZ can fully comply with all insurance provisions without the need for any waivers or modifications. 131
132
SUPPLEMENTAL COST PROPOSAL – PARKING ENFORCEMENT & STAFFING SERVICES • City of East Palo Alto • December 9, 2025 •
133
Northern California
Regional Office
5901 Christie Ave
•Suite 202•
Emeryville, CA 94608
P: (510) 250-2052
F: (510) 345-3478
lazparking.com
1 SUPPLEMENTAL COST PROPOSAL
December 9, 2025
Ms. Orly Amey
Assistant to the City Manager
City of East Palo Alto
2415 University Avenue
East Palo Alto, CA 94303
Subject: Proposal for Parking Enforcement and Staffing Services Dear Ms. Amey,
Thank you for the opportunity to provide the City with the requested five year pricing detail and a breakdown of our optional enhancements. LAZ appreciates the clarity of the City’s questions and welcomes the chance to reinforce how our proposed staffing model, community first enforcement philosophy, and Ambassador Program align with East Palo Alto’s goals for cleaner streets, predictable coverage, and responsive neighborhood service.

The supplemental pricing that follows reflects the same all inclusive approach presented in our proposal. Every service level includes all labor, supervision, new hybrid enforcement vehicles equipped with GPS and Samsara telematics, TurboData integrated handheld devices, uniforms with body cameras, training, safety gear, and the full operational infrastructure needed to stand up a modern, high performing parking enforcement program. The City will never see add on charges for fuel, maintenance, insurance, or technology replacements. Our fixed fee structure gives East Palo Alto predictable budgeting over the full term of the agreement and positions the program to scale smoothly as service needs evolve.

The annual increase applied from Year 2 through Year 5 reflects a modest three percent COLA consistent with current Bay Area labor market conditions. Each of the three service levels mirrors the staffing models and enforcement outcomes described in our proposal, giving the City flexible pathways that support baseline expectations, expanded coverage, or full twenty four hour operations.

Optional enhancements are listed separately, per the City’s request. These items strengthen community engagement, technology driven accuracy, and pre launch readiness. Several enhancements carry no cost to the City because they are already built into our labor plan or covered under the fixed annual fee structure.
134
Northern California
Regional Office
5901 Christie Ave
•Suite 202•
Emeryville, CA 94608
P: (510) 250-2052
F: (510) 345-3478
lazparking.com
2 Our team looks forward to discussing these options during the virtual interview, including how the Ambassador Program functions during the early acclimation period and how a partnership model with EPAPD can deliver consistent, visible, and trusted enforcement across all neighborhoods. LAZ remains strongly committed to supporting the City’s objectives and becoming a long term partner to the East Palo Alto community.

Sincerely,

CINDY HEFNER MUHAMMAD MANSOOR, PTMP
Regional VP, Northern California VP, Municipal Operations 5901 Christie Ave. Ste 202 949 South Coast Drive, Suite 515 Emeryville, CA 94608 Costa Mesa, CA 92626
O: (510) 250-2052 (714) 290-4854
[email protected] [email protected]
.
135
3 SUPPLEMENTAL COST PROPOSAL
Year 1 Year 2 Year 3 Year 4 Year 5
Fixed Monthly Invoice $17,474 $17,998 $18,538 $19,094 $19,667 Fixed Annual Cost $209,684 $215,975 $222,454 $229,128 $236,002 Fixed Monthly Invoice $25,135 $25,889 $26,665 $27,465 $28,289 Fixed Annual Cost $301,616 $301,616 $301,616 $301,616 $301,616 Fixed Monthly Invoice $33,039 $34,030 $35,051 $36,103 $37,186 Fixed Annual Cost $396,467 $408,362 $420,612 $433,231 $446,228 Annual Estimated Cost for Year 2 - Year 5 reflects a 3% COLA increase LPR with annual subscription (per unit) $25,000 $11,000 $11,000 $11,000 $11,000 Mobile friendly complaint submission form $0 $0 $0 $0
Community ambassador shifts (1 month prior to go live) $0 $0 $0 $0 Periodic joint “parking checkup” days with City staff $0 $0 $0 $0 Covered under Estimated Annual Cost
Covered under Estimated Annual Cost
Covered under Estimated Annual Cost
Optional Enhancements & Innovation
Option 1 - Baseline
Option 2 - Expanded
Option 3 - 24 Hour
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East Palo Alto City CouncilDecember 16, 2025

East Palo Alto City Council
December 16, 2025