Agenda packet, first session — East Palo Alto City Council, June 2, 2026 (part 1 of 3)

EAST PALO ALTO CITY COUNCIL

REGULAR SESSION AGENDA
Tuesday, June 2, 2026, 6:00 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.

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International numbers available: https://zoom.us/u/aMWYF4KT East Palo Alto City Council June 2, 2026 Agenda
1 1. CALL TO ORDER AND ROLL CALL

2. APPROVAL OF THE AGENDA

3. APPROVAL OF CONSENT CALENDAR

3.1 Development Code Text Amendment (ZTA25-002) to amend various Chapters and Sections of Title 18 (Development Code) of the East Palo Alto Municipal Code

3.2 Pride Month Proclamation

3.3 Juneteenth Proclamation

3.4 Consent to Waiver of Conflict
Recommendation:

By motion, waive the second reading and adopt an ordinance (Attachment 1) to:

1. Repeal, replace and amend various Chapters and Sections of the Development Code regarding site design, architectural standards, definitions, typographical errors, corner lot standards, refueling and service stations, setbacks of multi-family zones, tree removals by government/quasi-government entities, Temporary Use Permits (TUPs), alcohol sales at bonafide eating establishments, Conditional Use Permits (CUPs) for public and private schools, Home Occupations, and other areas as set forth therein; and:

2. Find the proposed Development Code Amendments to be exempt in accordance with CEQA Guidelines Sections 15061(b)(3) (common sense exemption), 15378(b)(5) (Not a Project), and 15183 (Projects Consistent with a Community Plan, General Plan, or Zoning) of the California Environmental Quality Act (CEQA) Guidelines
Recommendation:

Present the proclamation for Pride Month.

Recommendation:

Present the proclamation for Juneteenth.

East Palo Alto City Council June 2, 2026 Agenda
2 3.5 City Council Meeting Minutes

3.6 Mr. Mancini Proclamation

4. CLOSED SESSION

5. PUBLIC COMMENT

6. ADJOURN CITY COUNCIL REGULAR MEETING TO THE EAST PALO ALTO

SANITARY DISTRICT BOARD MEETING

7. EPASD PUBLIC COMMENT

8. APPROVAL OF EPASD CONSENT CALENDAR

8.1 EPASD FY 2026-27 Proposed Budget

9. EPASD BOARD MEETING INFORMATIONAL REPORTS

10. ADJOURN EAST PALO ALTO SANITARY DISTRICT BOARD MEETING AND

RECONVENE CITY COUNCIL REGUALR MEETING

11. INFORMATIONAL REPORTS

11.1 Parking Conditions along Woodland Avenue
Recommendation: Adopt a resolution authorizing the City Attorney to execute a consent letter agreeing to the joint representation by Goldfarb & Lipman LLP of City of East Palo Alto and Frolic Community regarding the development of housing cooperatives in the City, including 801 Donohoe Street Recommendation:

Adopt the May 19, 2026, City Council Meeting Minutes.

Recommendation: Present the proclamation.

4.1 CONFERENCE WITH REAL PROPERTY NEGOTIATORS
Property: 2120 Euclid, East Palo Alto, CA
Agency Negotiation: Melvin Gaines, City Manager, Tuan Pham, Downs Pham & Kieu LLP, John D. Lê, City Attorney
Under Negotiation: Price and Terms
Recommendation: Staff recommends that the EPASD Board receive this presentation and provide feedback on the Fiscal Year 2026-27 proposed budget.

Recommendation:

Receive the informational report and presentation.

East Palo Alto City Council June 2, 2026 Agenda
3 12. SPECIAL PRESENTATIONS

13. PUBLIC HEARINGS

13.1 City of East Palo Alto Vista 2035 General Plan Safety and Noise Element and Infrastructure, Services, and Facilities Element Update

13.2 Temporary Housing Development Incentive Program Ordinance Introduction (Continued to June 9, 2026)
Recommendation:

Adopt a resolution to:

1. Approve the proposed amendment to the East Palo Alto Vista General Plan 2035 to update the Safety and Noise Element and the Infrastructure, Services, and Facilities Element; and

2. Find that the amended elements comply with recent changes to California State Law governing General Plan Safety Elements; and

3. Incorporate the San Mateo County Multijurisdictional Local Hazard Mitigation Plan by reference including the City of East Palo Alto Annex into the Safety and Noise Element; and

4. Find that project is exempt pursuant to a common-sense exemption under CEQA Guidelines Section 15061(b)(3) because implementation of the proposed project would not have the potential cause a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA.

Recommendation:
(Continued June 9, 2026) Staff recommends that the City Council adopt a resolution to:

1. Waive the First Reading and introduce an uncodified ordinance titled “Temporary Housing Development Incentive Program (“THDIP”) to encourage the construction of new housing by reducing inclusionary housing obligations for residential developments, including the residential component of mixed-use projects, effective until December 30, 2027;

2. Direct the City Manager or designee to adopt Administrative Guidelines for the implementation of the THDIP; and

3. Find that the proposed actions do not constitute “projects” with the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b) (governmental, administrative or financial activity) and Section 15061(b)(3) (common sense).

East Palo Alto City Council June 2, 2026 Agenda
4 13. POLICY AND ACTION

14. COUNCIL REPORTS

14.1 Letter Regarding IHRA Adoption

15. ADJOURNMENT
Upcoming meetings:

June 9, 2026 Study Session Meeting 6:00 PM
June 16, 2026 Regular Meeting 6:00 PM
June 23, 2026 Study Session Meeting 6:00 PM
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: May 28, 2026
ATTEST:

James Colin
City Clerk
East Palo Alto City Council June 2, 2026 Agenda
5 CONSENT ITEM 3.1

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: June 2, 2026
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Shiri Klima, Assistant City Manager
Natasha Raiburn, Interim Director of Community & Economic Development Elena Lee, Planning Manager
Salifu Yakubu, Senior Planner
SUBJECT: Development Code Text Amendment (ZTA25-002) to amend various Chapters and Sections of Title 18 (Development Code) of the East Palo Alto Municipal Code Recommendation
By motion, :

1. Waive the second reading and adopt an ordinance (Attachment 1) to repeal, replace and amend various Chapters and Sections of the Development Code regarding site design, architectural standards, definitions, typographical errors, corner lot standards, refueling and service stations, setbacks of multi-family zones, tree removals by government/quasigovernment entities, Temporary Use Permits (TUPs), alcohol sales at bona fide eating establishments, Conditional Use Permits (CUPs) for public and private schools, Home Occupations, and other areas as set forth therein; and

Alignment with City Council Strategic Plan
This recommendation is primarily aligned with the following strategy:
 Land Use, Economic, and Workforce Development
6 Analysis
On May 5, 2026, at a publicly noticed hearing, the City Council waived the first reading and introduced an ordinance amending various sections of Title 18 (Development Code) of the East Palo Alto Municipal Code (EPAMC). The City Council discussed several proposed amendments to the Development Code. The amendments, grouped under the following four distinct categories, were previously discussed and recommended for approval by the Planning Commission at a publicly noticed hearing on March 23, 2026, including: (1) correct errors and omissions, (2) improve internal consistency, (3) streamline the development review process to support economic development, and (4) add Objective Design Standards to align the Development Code with State law.

On April 21, 2026, the City Council reviewed the first three categories and continued consideration of the fourth, Objective Design Standards (ODS), to the May 5, 2026, meeting.

The staff reports for aforementioned meetings are linked below:

March 23, 2026, Planning Commission staff report:
https://d3n9y02raazwpg.cloudfront.net/cityofepa/3a4abe4c-f279-11f0-bb28-005056a89546- b66d8e1b-5f57-400b-9799-cf3a802a8761-1773946417.pdf
April 21, 2026, City Council first reading staff report:
https://d3n9y02raazwpg.cloudfront.net/cityofepa/a7f7d725-d23b-11f0-bb28-005056a89546- 3408cd31-ecd7-4429-9d91-65986d552499-1776812344.pdf
May 5, 2026, City Council first reading (continued from 4/21/06) staff report:
https://d3n9y02raazwpg.cloudfront.net/cityofepa/f44a0fe3-d23b-11f0-bb28-005056a89546- 3408cd31-ecd7-4429-9d91-65986d552499-1778006791.pdf
The May 5, 2026, Council staff presentation covered the following design and architectural topics:
 General Site Design: Main entrances must be visible from public routes and half of ground-floor units need direct sidewalk or pathway access.  Site Access: Driveways should be placed to minimize pedestrian conflicts. Limit number of curb cuts per site and provide clear pedestrian routes between sidewalks and entrances.
 Loading: Loading and waste areas must minimize circulation conflicts, noise, and visibility from public areas through central placement, screening, and rear-oriented locations.
 Parking Design: Parking should be located behind buildings or screened beside buildings, and designed to prevent public street queuing. 7  Setback Area and Landscape Design: Setbacks require landscaping. Mature trees should be preserved, and permeable pavers should be used to minimize storm water impacts.
 Private and Common Open Spaces: Private spaces require screening and direct accessibility from living spaces; common spaces need landscaping, seating, open sky exposure, and dimensional standards proportionate to building heights.  Massing and Articulation: Buildings must reduce monotony through façade articulation, upper-story stepbacks, façade breaks, and human-scaled rhythmic architectural patterns.
 Compatibility and Transition: New development and additions must match surrounding character, preserve privacy, provide stepbacks, landscaping buffers, and bulk-reducing articulated façades.
 Façade Design and Activation: Ground floors of structured garages and mixed-use buildings facing public spaces require active uses and transparent façades, without extended blank walls.
 Architectural Design Detail: Buildings need articulated entrances, recessed windows, durable materials, screened rooftop equipment, and privacy-oriented residential groundfloor elevations or porches that are either recessed or projected.

The City Council discussed and approved all of the proposed amendments with one change to reduce the length of residential and mixed-use buildings to a maximum 250 feet and 300 feet respectively.

There were no public speakers.

The City Council introduced Ordinance (Attachment 1), as amended on the dais, with the following vote:

AYES: Abrica, Dinan, Lincoln, Romero
NOES: -
ABSENT: Barragan
ABSTAIN: -
This item is now before the Council for a second reading and adoption of the Ordinance.

Fiscal Impact
The proposed ordinance will not result in any negative fiscal impact to the City. 8 Public Notice
Notice of this agenda item was provided by posting the City Council agenda on the City’s official bulletin board outside City Hall, and by making the agenda and staff report available on the City’s website and at City Hall (2415 University Avenue, East Palo Alto). Additionally, a legal notice was published in a local newspaper by May 22, 2026, more than ten (10) days prior to the meeting.

Environmental
This ordinance is not subject to the California Environmental Quality Act (CEQA) because it does not constitute a "project" that would result in a direct physical change or a reasonably foreseeable indirect physical change to the environment, pursuant to CEQA Guidelines Section 15378.

Even if it were considered a project subject to CEQA, it would be exempt under CEQA Guidelines Section 15378 (regulatory actions) and Section 15061(b)(3), as there is no possibility that the Development Code, by itself, would have a significant adverse effect on the environment.

Furthermore, in accordance with CEQA Guidelines Section 15183, projects consistent with the development density established by General Plan policies (Vista 2035), for which an Environmental Impact Report (EIR) has already been certified, do not require additional environmental review, except where necessary to evaluate whether there are project-specific significant effects that are unique to the project or its site.

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. Draft City Council Ordinance with ODS as Exhibit A (Tracked)

2. Draft City Council Ordinance (Clean Copy)
9 ATTACHMENT 1
ORDINANCE NO.

AN ORDINANCE OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO
ADOPTING DEVELOPMENT CODE TEXT AMENDMENT ZTA25-002 AMENDING TITLE 18 (DEVELOPMENT CODE) OF THE EAST PALO ALTO MUNICIPAL CODE (EPAMC) SPECIFICALLY TO REPEAL AND REPLACE SECTION 18.10.040 – SITE DESIGN AND

ARCHITECTURAL STANDARDS WITH NEW OBJECTIVE SITE AND ARCHITECTURAL DESIGN STANDARDS; 2) AMEND CHAPTER 18.08 DEFINITIONS TO AMEND SECTION

18.08.010 – GENERAL TO ADD A DEFINITION FOR APARTMENT UNDER “A” DEFINITIONS, TO AMEND THE DEFINITION OF MULTI-FAMILY DWELLINGS UNDER “M” DEFINITIONS, TO ADD THE DEFINITION OF ROWHOUSE UNDER “R” DEFINITIONS, TO AMEND THE DEFINITION OF SINGLE-FAMILY DWELLINGS, ATTACHED UNDER “S”

DEFINITIONS, AND TO AMEND THE DEFINITIONS OF TOWNHOUSE AND TWO-FAMILY DWELLINGS UNDER “T” DEFINITIONS; 3) AMEND CHAPTER 18.96 TO CORRECT A TYPOGRAPHICAL ERROR IN “EXHIBIT K” WHICH WAS PREVIOUSLY ADOPTED BY THE CITY COUNCIL ON MARCH 18, 2025 AS “SECTION 18.96.030.A.4 – GENERAL PROVISIONS” CORRECTED TO “SUB-SECTION 18.96.030.E.4 – GENERAL PROVISIONS,” TO ADD THE MISSING TEXT “ADUS MUST NOT EXCEED THE” TO SUBSECTION 18.96.030.E.4.C, AND TO CORRECT TYPOLOGICAL ERRORS IN TABLE 2-3 OF SECTION 18.12.020 – LAND USE REGULATIONS AND ALLOWABLE USES REGARDING THE PERMISSION OF TWO-FAMILY DWELLINGS – ATTACHED ONLY IN THE MUC – MIXED USE CORRIDOR ZONE AND NOTATION UNDER SPECIFIC USE REGULATIONS FOR HOME BUSINESSES; 4) AMEND CHAPTER 18.10 TO AMEND SUBSECTION 18.10.030.E TO ALIGN WITH SUB-SECTION 18.96.050.F.3 CORNER LOTS AS ADOPTED BY CITY COUNCIL ON FEBRUARY 6, 2024, TO AMEND TABLE 2-2 AND ASSOCIATED “NOTES” OF SECTION 18.10.030 DEVELOPMENT STANDARDS TO

ALIGN WITH THE OPEN SPACE STANDARDS ADOPTED BY CITY COUNCIL ON FEBRUARY 6, 2025, AND AMEND THE FRONT AND SIDE SETBACK INCREASE OVER 18 FEET IN HEIGHT FOR SINGLE-FAMILY DWELLINGS AS PROPOSED TO BE REPEALED AND REPLACED PURSUANT TO SECTION 18.10.040 – OBJECTIVE SITE AND ARCHITECTURAL DESIGN STANDARDS; 5) AMEND SECTION 18.48.180 SERVICE STATIONS TO AMEND SUB-SECTION 18.48.180.B.3 AND TABLE 2-3 ALLOWED USES AND PERMIT REQUIREMENTS OF SECTION 18.12.020 TO ALLOW REFUELING AND

SERVICE STATIONS WITH CONDITIONAL USE PERMITS IN CERTAIN ROADWAY

CORRIDORS IN MIXED USE ZONES AND SCHOOLS, PUBLIC AND PRIVATE WITH CONDITIONAL USE PERMITS IN ALL MIXED USE ZONES; 6) AMEND CHAPTER 18.10 TO AMEND TABLE 2-2 OF SECTION 18.10.030 – DEVELOPMENT STANDARDS TO REDUCE THE MINIMUM FRONT SETBACK DIMENSIONS TO LIVING AREAS TO 15-FEET IN ALL RESIDENTIAL ZONES;7) AMEND CHAPTER 18.28 – TREES ON PRIVATE PROPERTY TO AMEND SUB-SECTIONS 18.28.070.E TO EXEMPT TREE REMOVAL

REQUESTS FROM UTILITY COMPANIES FROM THE REQUIREMENT TO SUBMIT AN ARBORIST REPORT WITH THE APPLICATION AND AMEND SECTION 18.28.110.A TO CORRECT THE REFERENCED CHAPTER UNDER VIOLATIONS FROM “1.118” TO “18.118”; 8) AMEND CHAPTER 18.08 – DEFINITIONS TO AMEND THE DEFINITION OF HOME OCCUPATIONS (HOME BUSINESSES) UNDER “H” DEFINITIONS IN SECTION

18.08.010 – GENERAL, AND AMEND CHAPTER 18.48 TO AMEND SECTION 18.48.110

HOME BUSINESSES (HOME OCCUPATION PERMIT) TO ALLOW HOME OCCUPATIONS IN ACCESSORY STRUCTURES WITHIN RESIDENTIAL PROPERTIES AND TO CLARIFY 10

PERMIT LIMITATIONS REGARDING THE OPERATION OF HOME OCCUPATIONS BY NEW RESIDENTS, 9) AMEND CHAPTER 18.94 TO STREAMLINE THE TEMPORARY USE PERMIT PROCEDURES, 10) AMEND CHAPTER 18.08 DEFINITIONS TO AMEND SECTION 18.08.010 TO ADD OR AMEND VARIOUS DEFINITIONS FOR ALCOHOL SALES AND DRINKING AND EATING ESTABLISHMENTS, 11) AMEND CHAPTER 18.48 –

REGULATIONS FOR SPECIFIC LAD USES AND ACTIVITIES TO EXEMPT INCIDENTAL

SALE OF ALCOHOL FROM CONDITIONAL USE PERMIT AND STREAMLINE / CLARIFY OTHER MISCELLANEOUS PROVISIONS, AND 12) AMEND TABLES 2-3, 2-5, AND 2-7 OF SECTIONS 18.12.020, 18.14.020, AND 18.16.020 RESPECTIVELY TO CORRECT AND CLARIFY CERTAIN NOTATIONS REGARDING ALCOHOL SALES AND FOOD SERVICE.

WHEREAS, Chapter 18.114 of the City of East Palo Alto Development Code allows for amendments to the Development Code and provides procedures for processing such amendments; and
WHEREAS, Section 18.114.060 of the City of East Palo Alto Development Code sets forth findings for Development Code amendments; and
WHEREAS, the Planning Commission of the City has reviewed the proposed amendments to the City of East Palo Alto’s Development Code at a duly and properly noticed public hearing on March 23, 2026 and considered all evidence, including but not limited to public testimony and the evaluations and recommendations of staff, and has found that the proposed amendments are consistent with the goals and policies of the City’s General Plan, and recommends adoption of the proposed amendments by the City Council of the City of East Palo Alto (“City Council”); and
WHEREAS, the City Council conducted duly and properly noticed public hearings on April 21, 2026, and May 5, 2026, to consider the proposed amendments to the Development Code and considered all evidence, including but not limited to public testimony and the evaluations and recommendations of staff, and finds and determines that the proposed amendments to the City of East Palo Alto Development Code are adopted pursuant to the City’s police power authority to protect the public health, safety, and welfare.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF EAST PALO ALTO DOES ORDAIN AS FOLLOWS:

SECTION 1. CHAPTER 18.10 AMENDED
Section 18.10.040 – Site Design and Architectural Standards is hereby repealed and replaced with Objective Site and Architectural Design Standards as shown in Exhibit “A”, attached hereto and incorporated herein by reference
SECTION 2. CHAPTER 18.08 AMENDED
Section 18.10.010 – General is hereby amended to add a definition for Apartment under “A” Definitions, to amend the definition of Multi-Family Dwellings under “M” Definitions, to add the definition of Rowhouse under “R” Definitions, to amend the definition of Single-Family Dwellings, Attached under “S” Definitions, and to amend the definitions of Townhouse and Two-Family Dwellings under “T” as shown in Exhibit “B”, attached hereto and incorporated herein by reference. 11
SECTION 3. CHAPTER 18.96 AMENDED
Sub-Sections 18.96.030.A.4 -General Provisions and 18.96.030.E.4.c are hereby amended as shown in Exhibit “C”, attached hereto and incorporated herein by reference.

SECTION 4. CHAPTER 18.12 AMENDED
Section 18.12.020 Table 2-3 Land Use Regulations and Allowable Uses is hereby amended as shown in Exhibit “D”, attached hereto and incorporated herein by reference.

SECTION 5. CHAPTER 18.10 AMENDED
Section 18.10.030 Development Standards is hereby amended as shown in Exhibit “E”, attached hereto and incorporated herein by reference, to reconcile the provisions for Corner Lots as previously adopted by Council.

Section 18.10.030 Table 2-2 is hereby amended as shown in Exhibit “F”, attached hereto and incorporated herein by reference, to align open space standards as previously adopted by Council.

Section 18.10.030 Table 2-2 NOTES is hereby amended as shown in Exhibit “F”, attached hereto and incorporated herein by reference, to amend Front and Side Setback Increase Over 18 Feet in Height For Single-Family Dwellings.

SECTION 6. CHAPTER 18.48 AMENDED
Sub-Section 18.48.180.B.3 is hereby amended as shown in Exhibit “G”, and Sub-Section

18.12.020 Table 2-3 is hereby amended as shown in Exhibit “H”, both attached hereto and incorporated herein by reference to allow Refueling and Service Stations and associated uses at certain locations , and Public and Private Schools with Conditional Use Permits in all Mixed Use Zones.

SECTION 7. CHAPTER 18.10 AMENDED
Section 18.10.010 – Development Standards is hereby amended as shown in Exhibit “I” to reduce the minimum front setback dimensions to Living Areas to 15-feet in all Residential Zones.

SECTION 8. CHAPTER 18.28 TREES ON PRIVATE PROPERTY AMENDED Section 18.28.070 Criteria for Tree Removal is hereby amended as shown in Exhibit “J”, attached hereto and incorporated herein by reference.

Section 18.28.110 Enforcement is hereby amended as shown in Exhibit “K”, attached hereto and incorporated herein by reference.

SECTION 9. CHAPTER 18.08 DEFINITIONS AMENDED
Sections 18.08.010.”H” Definitions is hereby amended as shown in Exhibit “L”, attached hereto and incorporated herein by reference.

Sections 18.48.110 Home Occupations (Home Businesses) is hereby amended as shown in Exhibit “M”, attached hereto and incorporated herein by reference. 12 SECTION 10. CHAPTER 18.98 AMENDED
Section 18.94.050 Allowed Temporary Uses, Section 18.94.060 Application Filing and Processing, Section 18.94.070 Director Review, and 18.94.110 Post Decision Procedures are hereby amended as shown in Exhibit “N”, attached hereto and incorporated herein by reference.

SECTION 11. CHAPTER 18.08 AMENDED
Section 18.10.010 – General is hereby amended to add and amend definitions for Alcohol Sales (off-site-sale), Alcohol Sales (off-site-sale)-Accessory, Alcohol Sales (on-site-sale), Alcohol Sales (on-site-sale)-Incidental, Drinking Establishments, and Eating Establishment as shown in Exhibit “O”, attached hereto and incorporated herein by reference.

SECTION 12. CHAPTER 18.48 AMENDED
Sub-Sections 18.48.040.A, 18.48.040.D.1, and 18.48.040.E.1.d are hereby amended as shown in Exhibit “P”, attached hereto and incorporated herein by reference.

SECTION 13. CHAPTERS 18.12, 18.14, AND 18.16 AMENDED
Sections 18.12.020 (Table 2-3), 18.14.020 (Table 2-5) and 18.16.020 (Table 2-7) 180.B.3 are hereby amended as shown in Exhibits “Q,” “R,” and “S” respectively, all attached hereto and incorporated herein by reference.

SECTION 14. CALIFORNIA ENVIRONMENTAL QUALITY ACT.

This Ordinance is not subject to the California Environmental Quality Act (CEQA) because it does not constitute a "project" that would result in a direct physical change or a reasonably foreseeable indirect physical change to the environment, pursuant to CEQA Guidelines Section 15378.

SECTION 13. SEVERABILITY.

If any section, subsection, sentence, clause, phrase or word of this Ordinance is for any reason held to be invalid by a court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this Ordinance. The City Council hereby declares that it would have passed and adopted this Ordinance, and each and all provisions hereof, irrespective of the fact that one or more provisions may be declared invalid.

SECTION 14. EFFECTIVE DATE.
13 This Ordinance shall take effect and be in full force thirty (30) days after the date of its adoption.

SECTION 15. PUBLICATION.

The City Clerk is hereby directed to cause publication of this Ordinance as required by Government Code Section 36933.

INTRODUCED at regular City Council meetings held April 21, 2026, and May 5, 2026, and PASSED AND ADOPTED at a regular City Council meeting held on , 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

Weber Lincoln, Mayor
ATTEST: APPROVED AS TO FORM:

James Colin, City Clerk John D. Lê, City Attorney

EXHIBITS
Exhibit A – Objective Site and Architectural Design Guidelines Exhibit B – Definitions
Exhibit C – Corrections to previously approved “Exhibit K”.

Exhibit D – Corrections to Table 2-3.

Exhibit E – Development Standards on Second Curb Cuts.

Exhibit F - Table 2-2 Reconciliation of Private Open Space standards and Front and Side setback increase.

Exhibit G – Service Stations and associated uses. 14
Exhibit H - Table 2-3 Allowed Uses and Permit Requirements Exhibit I - 15-foot Front and 5-foot Side Setbacks in Residential Zones
Exhibit J – Criteria for Tree Removals.

Exhibit K – Enforcement
Exhibit L – Definitions
Exhibit M – Home Businesses (Home Occupation Permits)
Exhibit N – Temporary Use Permits
Exhibit O – Definitions regarding Alcohol Sales, and Drinking and Establishments.

Exhibit P – Alcohol Sales
Exhibit Q – Corrections to Table 2-3.

Exhibit R – Corrections to Table 2-5.

Exhibit S – Corrections to Table 2-7.
15 EXHIBIT A

18.10.040 - Site Design and Architectural Standards
A. Purpose.

Site design and architectural standards are established consistent with General Plan policy to promote quality design of new residential structures and additions. The City recognizes that quality design promotes longer life of structures, improves the appearance and maintenance of neighborhoods, and increases value in the housing stock.

B. Applicability.

In addition to the standards specified as applicable to all zones and the regulations for specific land uses and activities, the following site design and architectural standards shall apply to all new residential structures and additions to existing residential structures. The design standards are organized by housing type as follows:
• Single-Family, Two-Family, Triplex, Fourplex and Townhouse, as defined in Chapter 18.08 (Definitions).
• Apartments and Mixed Use Buildings, as defined in Chapter 18.08 (Definitions).

C. Single-Family, Two-Family, Triplex, Fourplex and Townhouse

1. General Site Design Standards
a. All new residences or residential additions shall be designed to match the prevailing front setback condition as viewed from the street and measured as an average of all front setbacks along the same block face. (Figure 1)
b. Front entries shall include stoops and/or porches and be identifiable through architectural details such as awnings, projections, or recesses. Primary unit entrances for single-family and townhouse buildings shall be visible from the street.
c. For buildings located at the front of a lot, any horizontal offset from the center of the street curb cut and the center of the garage door opening shall be less than 4 feet, in order to maintain a horizontal alignment and reduce pedestrian conflict. (Figure 2) d. For townhouse and multiplex buildings, pedestrian paths shall be provided to each individual ground-floor unit entrance and to connect units to common open space areas and parking areas.

Figure 1. FRONT SETBACK CONDITION
Figure 2. GARAGE DOOR ALIGNMENT
16 2. General Site Design Guidelines
a. To the maximum extent possible, orientation of structures and windows should take advantage of natural light and wind patterns for natural heating and cooling. b. Driveways should be placed in a manner that avoids conflict with pedestrian access from the sidewalk.

3. Setback Area & Landscaping Design Standards
a. Front yard landscaping shall be provided consistent with landscaping requirements including the limitation of pavement to maximum 50% of the front yard. b. To the extent required by Chapter 18.28 (Trees on Private Property) of the East Palo Alto Municipal Code (EPAMC), existing mature, healthy trees shall be preserved in association with new construction, any remodeling or additions.
c. Pervious or semi-pervious surfacing materials shall be used as needed to meet C.3. New Development and Redevelopment (stormwater and drainage) requirements for pedestrian paths and driveways. Recommendations and regulations for pervious pavement as provided in Section 6.6 of Chapter 6 (Technical Guidance for Specific Treatment Measures) of the San Mateo Countywide Water Pollution Prevention Program (Flowstobay).

4. Massing and Addition Standards
Intent: All new single-family, two-family, triplex, fourplex or townhouse buildings and residential additions should be designed to respect or complement the existing development pattern and massing as viewed from the street. An addition should be designed so that it appears to be part of the original structure.
a. Residential second/third-story additions shall employ at least two of the following building modulation strategies:
(i) Varied roof forms, including but not limited to changes in roof height, offsets, dormers, etc. (ii) Use of balconies, front porches, decks, overhangs, or covered patios. (iii) Projections, offsets, and/or recesses of the building wall at least 2 feet in depth, such as bay windows.
17 b. If the addition includes a large wall plane (longer than 20 feet), the plane shall incorporate at least two of the following architectural elements with bay window extensions, trellis features, recessed doors or windows, as follows:
a. A projection or recess with a minimum depth of 24 inches and a minimum width of 4 feet (e.g., bay window, wall offset)
b. A trellis or similar vertical feature covering at least 15% of the wall plane area. c. Door or window openings recessed a minimum of 4 inches from the wall surface d. Additional architectural detailing (e.g., material changes, trim, or reveals) that creates a minimum of one horizontal or vertical break per 20 feet of wall length c. All facades visible from a public right-of-way shall maintain a consistent design across the structure, incorporating the typical elements of the selected architectural style.

5. Massing and Addition Guidelines
a. The bulk and mass of new single-family residential structures and additions should match the scale of existing structures in the same residential block. b. Additions to residential structures should be designed and constructed to match the architectural style and building form of the structure to which they are added. c. All second story additions should be designed as a series of smaller building volumes as opposed to a single massive structure.
d. The use of eaves, dormers, intersecting hips or gables, or other roof features are encouraged to add visual interest and break up the mass of the structure. e. All additions to existing single-family residences should be architecturally consistent with the existing residence with respect to roof pitch and tie-in, exterior materials, and colors.

6. Privacy Standards
Intent: New residences and residential additions should be designed to preserve privacy, light, and air to adjoining properties to the extent feasible.
a. Second/third story additions shall step back from the front of the dwelling (the first story) by at least ten feet if the prevailing block condition is single-story (more than 60% of existing structures are single-story).
b. To preserve light and air for adjoining properties, where a new structure or an addition to an existing single-family structure will exceed 22 feet in height, the required setback from the side property lines of the site shall be increased by one foot for each two feet of structure height in excess of 22 feet; the increased setbacks are to be imposed only with respect to that portion of the new structure or addition that exceeds 22 feet in height. (Figure 3) 18 Figure 3. NEW ADDITIONS
c. Balconies that project outward from the structure (extending beyond the first-floor façade) shall be located a minimum of 20 feet from a shared rear or side property line. Inset balconies are exempted from this requirement. See Figure 4.

Figure 4. BALCONY SETBACKS
19 d. When a new structure or addition is located within five feet of a side property line, upper floor windows on the building shall be oriented to avoid a direct line of sight into adjacent residential buildings or property (Figure 5):
(i) Windows shall be offset a minimum of three feet horizontally from windows of the nearest residential building on the adjacent property to maximize privacy. (ii) Windows on any floor to a non-habitable room such as a bathroom or closet may be excepted from this standard if both the following conditions are met:
a) The minimum windowsill height is six feet.
b) The window has frosted or privacy glass.
(iii) This standard shall be waived if there is a conflict with any Building Code requirements.

Figure 5. WINDOW LOCATION
e. A landscaped planter strip at least five feet in width shall be provided along the abutting interior property lines between a new structure or addition and any adjoining single-family residential units or single-family residential zoning district boundaries (except within the required front setback). The planter strip shall contain living plant material consisting of trees, shrubs, or hedges) arranged to achieve a continuous visual screen. At the time of planting, materials shall be selected and spaced so that, with five years of installation, they form a screen at least six feet in height and at least 75 percent coverage when viewed horizontally from the adjacent single-family residential uses. All landscaping shall be installed prior to final inspection or occupancy and maintained in a healthy, living condition. Installation and maintenance shall be 20 in accordance with the Chapter 18.28 (Trees on Private Property), Chapter 18.10 (Residential Zones), Chapter 18.12 (Mixed Use Zones), Chapter 18.26 (Fences, Hedges and Walls), and Chapter 18.28 (Trees on Private Property) of the EPAMC.

Multiple rooflines and materials are permitted only when they are intentionally integrated into a cohesive architectural composition that demonstrates clear alignment, proportional relationships, and a unified material palette.
c. Garages
(i) Garages that are oriented toward the street (“front-loaded”) shall have a maximum width of 22 feet and shall comprise no more than 60% of the total façade width. The garage doors shall be located at least 23 feet from the public street. Standards for townhouse garages are provided in section iii below.
(ii) All attached or detached garages shall be set back at least six feet behind any living spaces. (Figure 6)
(iii) Tuck-under parking for townhouses shall follow the following standards: (Figure 7) a) Townhouse garages shall be accessed from an alley (or another internal road or driveway) and shall not exceed 75% of the townhouse frontage. b) A garage door shall not exceed 22 feet in width.
c) Garage doors shall be located a minimum of 2 feet from one another. d) For tuck-under parking along alleys, landscaping shall be located between garage doors and include a planting area or planter box with a minimum 12-inch length and width. 21 Figure 6. ATTACHED OR DETACHED GARAGES
Figure 7. TUCK-UNDER PARKING

8. Architectural Design Detail Guidelines
a. If there is a predominant architectural style or consistent use of exterior materials in the residential block (with at least 60% of residences), then the architectural style or exterior materials should be consistent with or complement the use of exterior materials in the neighborhood.
b. Window and door design and placement should be consistent (similar to) with the overall architectural style of the structure.
c. Roof style and pitch should be consistent with roof style and pitch in the vicinity. 22 D. Apartments And Mixed Use Buildings

1. General Site Design Standards
a. The main entry shall be located onto the most predominant travel way including a public street, pedestrian paseo/greenway, or publicly accessible plaza. Secondary entrances may be located on private streets or open spaces.
b. The main entry shall be visible and easily accessible for pedestrians from the public street. c. Entrances to individual residential units shall be accessible from the street, internal corridors, or from common open space areas within the development. d. A minimum of 50% of ground floor units shall have an entry directly accessible from the closest sidewalk or pedestrian path.

2. General Site Design Guidelines
a. All new structures should be designed to respect or complement the existing development pattern as viewed from the street.
b. Multi-family buildings should generally be located and oriented as close to the front setback as possible; stoops, forecourts, public spaces, or plazas may encroach into the front setback and are excepted.
c. Mixed-use buildings (or any building with an active frontage) should be located as close as possible to the front setback line or immediately behind a public or semi-private space, such as outdoor seating for a restaurant. Excessively large front setbacks are strongly discouraged.
d. Mixed-use developments should not exceed a maximum block perimeter of 1,400 feet.

Blocks may be broken up by private or public streets, publicly accessible service streets/fire access streets, or greenways/paseos.
e. Mixed-use buildings should be oriented toward the street, so that they frame the pedestrian environment.
f. Multi-family and mixed-use buildings should be arranged to create well-defined areas for plazas, green spaces, and pathways.
g. Where feasible, the main entrance of a corner building should be located at the corner (preferably within 25 feet of the corner). When plazas/open spaces are located at a corner, the building should have direct pedestrian access off the plaza.

3. Site Access Standards
Intent: Driveways should be placed in a manner to avoid conflict with pedestrian access from the sidewalk.
a. Driveways shall not exceed 26 feet in width (driveways serving regular truck traffic may not exceed 30 feet in width).
b. A clear pedestrian path of travel shall be provided between the public sidewalk and the primary building entrance(s). Pedestrian paths shall be clearly delineated with pavement materials and/or markings and signage.
c. Each project site shall be limited to one curb cut (including driveways, service streets and alleys) per 200 feet of public street frontage, unless otherwise required for emergency vehicle access. Two curb cuts are permitted for parking garage frontage. On public street frontages, curb cuts shall be located a minimum of 50 feet from street corners. 23 4. Site Access Guidelines
a. Pedestrian access from the street and the parking lot to the main door of the structure should be designed to avoid conflict with vehicular traffic. b. Common (shared) driveways between adjacent uses or sites are encouraged.

5. Loading Standards
Intent: Loading areas should be designed and located to avoid conflicts with interior pedestrian and vehicular circulation, and to minimize noise and other impacts on adjacent uses. a. Loading and solid waste/recycling collection areas shall be centrally located so as to provide easy direct access to all residents and collection vehicles, and to minimize noise impacts on residents.
b. Loading docks, and equipment areas shall be screened from adjacent properties and publicly accessible streets and paths with fencing or walls, and landscaping and not be visible from a point six feet above ground. The enclosure shall achieve at least 90% opacity when viewed perpendicular to the enclosure. Landscaping, where used, shall consist of evergreen plant materials capable of achieving a minimum height of 6 feet and 80% yearround opacity within 3 years of installation. Chain link fencing with or without slats is not allowed.
c. Designated loading docks, bays, and spaces shall be located in the rear or interior side yard areas.
d. Exception: If loading to the rear or side is not feasible on a corner lot, loading may be located on a non-primary street (“side street”) frontage if the loading dock is set back at least 50 feet from the back of curb or the property line (whichever is greater); is screened with materials matching the primary building as follows:
(i) Exterior wall materials shall be identical in type; (ii) Color and texture shall be identical as used in the overall site and building design; (iii) Architectural detailing (trim, cornices) shall use the same profiles and dimensions as those used on the primary building;
(iv)The screening material shall be opaque with a minimum height of 6 feet and maximum height of 9 feet. This requirement does not apply to private streets.

6. Parking Design Standards
a. Surface parking shall be located behind any buildings. If that is not feasible, surface parking may be located beside buildings if screened from the street with low walls and landscaping. (Figure 8)
b. Wherever possible, reciprocal access to parking areas between adjacent non-residential uses should be provided as long as each site provides its required parking, subject to the approval of the Director.
c. Surface parking lots shall be screened from adjacent publicly accessible streets as per landscaping standards in EPAMC 13.24.430.
d. Above grade structured parking structures facing a public street or publicly accessible open space shall have only the driveway(s) and the garage entry lobby visible, with the remaining façade length of the first story (ground floor) lined or wrapped with commercial or habitable uses with a minimum depth of 25 feet.
24 e. On upper levels, structured parking that comes to the façade edge shall be designed to resemble a non-parking use or be designed with artistic/architectural features and articulation by incorporating the following features on each street facing façade:
(i) Transparent or translucent windows covering a minimum of 30% of the façade; (ii) Horizontal or vertical articulation consistent with section D.10.c of Massing and Articulation Standards;
f. In order of preference (with the highest first), structured parking garages shall face and be accessed from:
(i) Alleyway
(ii) Private Street/Internal Street
(iii) Public Street, Side Street
(iv) Public Street, Corridor or Primary Street
(v) Public Open Space
g. All automated and stand-alone structured parking facilities shall submit a parking access plan that meets the following standards:
(i) Access control designed to accommodate peak demand without causing vehicle queuing in the public right-of-way
(ii) An appropriate number and location of entries and exits (iii) Adequate internal circulation
(iv) Signage for drivers and pedestrians
(v) On-site queuing
Figure 8. SURFACE PARKING SCREENING
25 7. Setback Area & Landscaping Design Standards
a. Front yard landscaping shall be provided consistent with landscaping requirements in EPAMC Sections 13.24.330, 17.06, and 18.30.090 and the City’s Urban Forest Master Plan. Setbacks shall be landscaped and/or hardscaped.
b. Existing mature, healthy trees shall be preserved in association with any remodeling or addition projects, as per the City’s Tree Protection Ordinance. c. Pervious or semi-pervious surfacing materials shall be used for pedestrian paths and driveways.
d. Underground parking shall not encroach under public streets or dedicated public parks and shall not be located under Public Utility Easements (PUEs). Underground parking, when fully below grade, may encroach into setbacks and below privately owned open space. e. Asphalt paving is not permitted in private or common usable open spaces. f. Setback areas in multifamily and mixed-use developments shall be landscaped according to the following standards:
(i) Building setbacks abutting ground floor residential uses shall be landscaped or include planter boxes for a minimum of 75% of the required setback area excluding areas for patios, porches, stoops, fire escapes, stair landings, and required walkways. For street frontage locations where the setback between the back-of-walk and building façade is 15 feet or greater, a minimum 1 tree per 40 linear feet of building frontage shall be planted within that setback area.
(ii) Building setbacks abutting ground floor storefront retail uses shall be landscaped and/or include planter boxes for a minimum of 25% of the setback area. (iii) Building setbacks abutting other ground floor non-residential uses (other than active uses such as restaurants or retail) shall be landscaped a minimum of 60% of the setback area.

8. Private and Common Usable Open Space Standards
a. Private Open Space areas in multi-family residential and residential mixed-use projects are intended for private use for each dwelling unit and may include balconies (covered or uncovered), private gardens, private yards, terraces, decks, and porches, among others.

Private Open Space shall meet the following standards (spaces may be provided that do not meet the standards below but they may not be counted toward the required Private Open Space):
(i) Floor to ceiling height shall have a minimum dimension of 9 feet. (ii) May be covered but not fully enclosed.
(iii) Be directly adjacent to and accessible from the dwelling unit it serves. (iv) Ground level private open space shall be screened or buffered from adjacent private or common open space and dwellings by landscaping, fencing, walls, trellises, or other screening elements.
b. Common Usable Open Spaces are outdoor open spaces in multi-family residential and residential mixed-use projects that are shared and accessible only to building residents and their visitors. Common open spaces may include courtyards, gardens, play areas, outdoor dining areas, recreational amenities, and rooftop open spaces. Spaces may be provided that do not meet the standards below, but they may not be counted toward the required 26 Common Usable Open Space. Common Usable Open Space shall meet the following standards:
(i) Shall be immediately adjacent to entrances, hallways, lobbies, or residential units. (ii) Shall be accessible to all residents.
(iii) A courtyard enclosed by three sides of a building shall have a minimum open-end width that is equal to or greater than 75% of the highest height of the adjoining faces. Any dimension shall be a minimum of 20 feet wide. (Figure 9) (iv) Fully enclosed courtyards shall have one minimum dimension that is equal to or greater than the highest height (up to 80 feet) of the adjoining facades. The second dimension shall be equal to or greater than 80% of the highest height of the adjoining facades. Any dimension shall be a minimum of 20 feet wide (Figure 10) (v) A minimum of 60% of the open space area shall be open to the sky and free of permanent weather protection or encroachments. Trellises and similar open-air features are permitted.
(vi) A minimum of 20% of the required open space area shall be planted with trees, ground cover, and/or shrubs.
(vii)Shall have permanent seating.

Figure 9. THREE-SIDE ENCLOSED COURTYARDS
27 Figure 10. FULLY ENCLOSED COURTYARDS

9. Private and Common Usable Open Space Guidelines
a. Open spaces and pedestrian pathways should incorporate high-quality paving materials such as stone, concrete, pavers, or brick.
b. Internal open spaces should be designed to allow for maximum solar access and natural sunlight.
c. For non-residential portions of mixed-use projects, employees should be provided with breakrooms and open spaces that are an adequate size and are located in areas buffered from vehicle traffic and circulation.
d. Landscaping should be used to activate building façades; soften building contours; highlight important architectural features; screen less attractive elements; add color, texture, and visual interest; and provide shade.
e. Plants should be chosen that are well adapted to the climate of East Palo Alto. These plants may include native or other drought resistant plants. Refer to EPAMC Section 17.06 for additional guidance.
f. The amount of turf grass in landscaping should be minimized, and alternatives to turf should be used where practical. Consult the City’s Water Conservation in Landscaping Ordinance for additional requirements.

10. Massing and Articulation Standards
Intent: Structures should be designed to avoid long, monotonous, plain facades. Appropriate articulation techniques (i.e., staggered building planes, variation of facades, recessed entries) and arcades should be used to create variety and interest. a. Buildings shall not exceed 300 feet in length in mixed-use zones (MUL, MUC, MUH).

Buildings shall not exceed 250 feet in length in R-zones (R-LD, R-MD, R-HD, R-UHD). 28 b. Residential and mixed-use buildings greater than four stories in height shall reduce the massing of upper floors by a minimum of 10% of floor area for floors above the fourth (compared to the floor area of the ground floor).
c. For buildings three stories and taller, façades above the ground floor (or second floor if mixed-use) shall incorporate “breaks;” structural or design articulations that break large expanses down into smaller parts.
(i) The façade planes of residential-only and mixed-use residential buildings shall not exceed 100 feet in length without a façade break. For every 100 feet, provide a minimum of one large break, two medium breaks, or three minor breaks. (Figure 11 and Figure 12)
(ii) The size of the breaks in the façade plane should be sized depending on overall length of the façade and the number of breaks per facade:
a) Large Break. If one break is provided, the break should have a minimum width of 15 feet and a minimum depth of 10 feet.
b) Medium Break. If two breaks are provided, each break should have a minimum width of 10 feet and a minimum depth of 5 feet.
c) Minor Break. If three or more breaks are provided, each break should have a minimum width of 6 feet and a minimum depth of 3 feet.
(iii) These breaks shall continue through the ground floor façade for residential buildings, but do not need to do so for mixed-use buildings.

Figure 11. BREAKS FOR MIXED-USE
29 Figure 12. BREAKS FOR RESIDENTIAL ONLY
d. For residential and mixed-use facades, buildings shall establish a human-scaled rhythm with smaller individual building bay widths between 20 to 45 feet. This may be achieved with vertically-oriented building modulation, facade articulation, and/or repeating vertically oriented patterns of fenestration.

11. Massing and Articulation Guidelines
a. Large development projects should be designed as a complex of buildings rather than a single large structure.
b. Generally, a unified architectural and design theme should be applied to all structures within a development.
c. Structures should be designed and articulated to avoid long, monotonous, plain facades. d. Buildings should be designed with the human scale in mind, incorporating overhangs, changes in wall planes and building height, vertical elements, and other architectural features to break up the bulk of a single building and provide visual interest. Buildings should be broken up into smaller masses, particularly on upper levels. e. Windows, doors, and other openings should be designed to help implement the massing and articulation standards above.
f. The bulk and mass of new multifamily and mixed-use structures and additions to existing structures should be sensitive to the scale of structures in the immediate neighborhood. g. The scale and massing of structures should support a pedestrian-oriented ground-floor environment.

12. Compatibility and Transition Standards
Intent: All new residential buildings or residential additions should be designed to respect or complement the existing development pattern and massing as viewed from the street, providing a transition when appropriate. An addition should be designed so that it appears to be part of the original structure. 30
a. Additions to existing multifamily residential structures shall be designed and constructed to match the architectural style and building form of the structure(s) to which they are added by using identical exterior materials, window proportions within +/-10% in height-to-width ratios, fenestration and roof form of the existing building. b. Windows, balconies, and similar openings shall be oriented to preserve privacy of individual units within the development. When a new structure or addition is located within five feet of a side property line, upper floor windows on the building shall be oriented to avoid a direct line of sight into adjacent residential buildings or property by utilizing the following standards: (Figure 13)
(i) Windows shall be offset a minimum of three feet horizontally from windows of the nearest residential building on the adjacent property to maximize privacy. (ii) Windows on any floor to a non-habitable room such as a bathroom or closet may be excepted from this standard if both the following conditions are met:
a) The minimum windowsill height, if provided, is six feet. b) The window has frosted or privacy glass.
(iii) Balconies that project outward from the structure (extending beyond the first-floor façade) shall be located a minimum of 20 feet from a shared rear or side property line.

Inset balconies are exempted from this requirement. (Figure 14) (iv) The standards (i, ii, and iii) in this section shall be waived if there is a conflict with any Building Code requirements.
31 Figure 13. WINDOW LOCATION FOR PRIVACY
Figure 14. BALCONY SETBACK
32 c. A landscaped planter strip at least five feet in width shall be provided along the abutting interior property lines between a new structure or addition and any adjoining single-family residential units or single-family residential zoning district boundaries (except within the required front setback). Landscaping (trees, shrubs, or hedges) shall be planted within this strip, depending on the tree/plant species and canopy at maturity, to provide screening for adjacent single-family residential uses. All landscaping shall be installed in accordance with the EPAMC Chapters 18.28 (Trees on Private Property), 18.10 (Residential Zones), 18.12 (Mixed Use Zones), and 18.26 (Fences, Hedges and Walls), as applicable. d. When a building has a rear and/or interior side property line abutting a single-family residential zoned parcel (R-LD), starting above the third floor, each subsequent floor shall be stepped back by 10 feet for every two floors.
e. Vegetation used to screen views of a new residence or residential addition shall:
a. Achieve a minimum height of 6 feet within 3 years of planting; b. Provide at least 80% opacity year-round when viewed from adjacent properties; c. Be planted at intervals not exceeding 5 feet on center for shrubs or 15 feet on center for trees.
f. For a front or back building façade condition within the same site, building-to-building separation shall be a minimum of 45 feet for 4-story buildings or higher, a minimum of 35 feet for 3-story buildings and a minimum of 25 feet for 2-story buildings. g. For a side building façade condition within the same site, building-to-building separation shall be a minimum of 25 feet for 4-story buildings or higher, a minimum of 20 feet for 3- story buildings and a minimum of 15 feet for 2-story buildings. h. Building façades greater than 200 feet in length shall have at least two distinct façade compositions with at least two unique features of rhythm and pattern; material and color; modulation of building form; or façade articulation. Each of the compositions shall account for a minimum 20% of the total façade (Figure 15), and shall differ from the other in at least two of the following measurable ways:
a. Material type;
b. Color (minimum 15% difference in Light Reflectance Value (LRV)); 33 c. Plane offset of at least 12 inches;
d. Window pattern or spacing differing by at least 20%
Figure 15. FAÇADE COMPOSITION

13. Compatibility and Transition Guidelines
a. New multi-family residential buildings and residential additions should be designed to preserve privacy, light, and air to adjoining properties to the extent feasible. b. Where the original structure has limited design quality, the addition should work to enhance the overall appearance of the site.
c. Multi-family and mixed-use structures (containing both residential and commercial uses) adjacent to single-family or townhouse residential uses should incorporate sensitive transitions in scale and massing. For example, massing should be broken down using height step-backs, articulated sub-volumes, and horizontal and vertical façade articulation.

14. Façade Design and Activation - General Ground Floor Standards a. All ground-floor building frontages facing public streets, public open spaces, and common open spaces shall include operable entrances and/or transparent windows serving interior spaces for lobby use, living, working, neighborhood commercial, or other commercial spaces. Frontages facing service streets, alleys, rear lot lines, or private open space are not expected to have active uses.
b. Long blank walls (longer than 30 feet) without openings such as doors or windows are prohibited along facades facing public streets, public open space, or private streets with public access easements. 34
c. Parking structures shall be wrapped with ground floor uses along all street frontages. In lieu of ground floor uses, murals/art and landscaping are allowed on frontages facing service streets, alleys, rear lot lines, or private open spaces.

15. Façade Design and Activation - Residential Ground Floor Standards a. To provide adequate privacy for ground floor residential units in mixed-use zones, the closer the building is located to the back of sidewalk, the more elevated the ground-floor units shall be as follows:
(i) A building with a setback of 10 feet or less shall elevate units by at least 4.5 feet from the sidewalk level. (Figure 16). Alternatively, the units shall be provided with a canopied porch recessed or projected a minimum of two feet.
(ii) A building with a setback of 10 – 15 feet shall elevate units by at least 3 feet from the sidewalk level. (Figure 17). Alternatively, units shall be provided with a canopied porch recessed or projected a minimum of two feet.
(iii) A building with a setback greater than 15 feet does not need to elevate units. (Figure 18) Figure 16. GROUND FLOOR UNITS, LESS than 10 foot setback 35 Figure 17. GROUND FLOOR UNITS, 10-15 foot setback
Figure 18. GROUND FLOOR UNITS, more than 15 foot setback

16. Façade Design and Activation - Retail and Office Ground Floor Standards a. Ground floor retail and commercial storefronts shall have a minimum depth of 25 feet and a minimum floor-to-floor height of 16 feet.
b. On ground floor facades that face a public street, transparent glass windows shall be used that provide views into active interiors as follows: 36 Table 1: Glazing & Transparency Standards
Standard Storefront Office / Active NonResidential
Minimum Transparency
between 2 and 7.5 feet
65% 40%
Entrance Frequency Every 50 feet on average Every 80 feet on average

17. Façade Design and Activation - Upper Floor Façade Design Standards a. Balconies, where provided, shall utilize railing constructed of metal, glass, wood, or composite materials and shall match one of the primary exterior materials used on the building façade. Finishes shall match or fall within a 10% LRV range of the primary façade color scheme.
b. Each facade exposed to public view shall include two of the following architectural features, landscaping, or art elements:
o Balconies with a minimum projection of 3 feet;
o Planter boxes with a minimum depth of 12 inches;
o Public art permanently affixed and covering at least 20 square feet; o Façade material changes covering at least 20% of the façade area. c. Blank end walls (without windows, porches, or balconies) shall be prohibited. Windows, balconies, or other modulation shall be provided for at least 10% of the façade area. d. Roof flashing, rain gutters, down spouts, vents, and other roof protrusions shall be screened from view or finished with materials and colors identical to the adjacent. e. All facades of a building facing a street or public space shall incorporate variations in massing and articulation such as horizontal and vertical offsets of at least 12 inches in depth.

18. Façade Design Guidelines
a. Building façades should be designed to have a distinct base, middle, and top. b. Ground-floor façades should be designed to give individual identity and visual interest to each individual establishment.
c. Commercial frontages should be broken into similar 20- to 35-foot wide modules. d. Where multiple tenant spaces are incorporated into a building, individual tenant spaces should be located within distinct building bays. This can be achieved by any of the following:
(i) Placing a column, pier, or pilaster between façade elements. (ii) Applying a vertical slot or recess between façade elements. (iii) Providing variation in plane along the building wall. (iv) Modulating the building wall by recessing storefront entrances or creating a niche for landscaping or for a pedestrian area.
(v) Varying wall materials.
e. One or more of the following elements should be used to articulate a building façade:
37 (i) Variation in the details for the top of a building, including cornice lines, parapets, eaves, brackets, and other detailing.
(ii) Variation in the details for the body, or middle, of the building, including awnings, overhangs, canopies, pilasters, columns, slots, decorative lighting, and window boxes. (iii) Variation in the details for the base of a building, including recessed entry areas, covered outdoor areas, and alcoves.
f. Façade details should appear integral to the architectural and structural design of the building rather than tacked onto the surface.

19. Architectural Design Detail Standards
a. Entries
(i) The main shared entry to the multi-family or mixed-use development shall be clearly delineated and identifiable, with a massing projection or recess with a minimum depth of 2 feet.
b. Windows and Balconies
(i) Windows facing a public right-of-way or publicly accessible open space shall be recessed a minimum of 2 inches to provide a “punched” recessed character or window trim shall be provided with a minimum of 2 inches in width and depth. (Figure 19) (ii) Windows that are flat or “flush” with the façade are prohibited unless applied to a portion of a building that is part of a recessed façade modulation that is recessed at least 4 inches. (Figure 20)
Figure 19. WINDOW DESIGN
38 Figure 20. WINDOWS IN RECESSED FAÇADE MODULATIONS
c. Materials
(i) At least two materials shall be used on any building frontage, in addition to glazing and railings.
(ii) A maximum of three primary exterior materials and finishes shall be used on any façade. Each material shall cover at least 20% of the façade area, excluding windows and doors. The same materials shall be consistently applied to all facades, with no façade excluding a material used on another facade by more than 30% of its coverage. (iii) Plywood, vinyl, T1-11, plastic (and plastic laminate), and fiberglass shall be prohibited as siding materials.
(iv) Materials shall continue around corners for at least two feet. (Figure 21) (v) Vinyl and plastic awnings are prohibited.

Figure 21. MATERIAL CORNER TREATMENT
39 d. Roofs
(i) Roof style and pitch shall be consistent with the style and pitch of other roofs within the development. . Roofs within a development shall have pitches within ±2:12 of each other and shall use the same roof form (e.g., gable, hip, flat) on at least 75% of buildings.

Roofing materials shall be identical in type.
(ii) Additions to existing structures shall be designed to match the roofline, style, and colors of the original structure as follows:
o Roof pitch within ±2:12;
o Same roof form type;
o Roofing materials identical;
o Color within a 10% LRV range of the existing roof.
e. Roof-Mounted Equipment/Amenities
(i) All rooftop equipment shall either be:
a) Set back from the parapet or roof edge at a ratio of at least 1:1.15 (the height of equipment closest to the edge compared to its distance from the edge), and no less than 5 feet from edge regardless of height.
b) Screened with parapet walls or other architectural features such that the equipment is not visible from any point below the roof level. Screening more than 10 feet in height (that is flush with the building façade) shall be counted towards the maximum height.
(ii) All roof-mounted mechanical, electrical, and external communication equipment, such as satellite dishes and microwave towers, shall not be visible from a point 6 feet above grade at any property line. Screening materials shall be identical to primary building materials and shall fully enclose the equipment with a minimum opacity of 90%.
(iii) Roof-mounted equipment greater in height than the parapet wall shall be screened to a height equal to the height of the equipment such that it is not visible from any point at or below the roof level of the subject building.
(iv) Mechanical equipment that is less than two feet in height, solar panels, wind generators, or green roof features shall be exempt from these requirements. (v) Trellises, pergolas, or other amenity uses of the rooftop are limited to 20% of the total rooftop area (and each individual element may not exceed 400 square feet), must be set back by at least 10 feet from the roof edge, and may exceed the maximum building height by no more than 15 feet.

20. Architectural Design Detail Guidelines
a. Doors and Windows
(i) Main building entrances should be oriented toward the sidewalk and include architectural features that give them prominence. Treatments such as a change in height or a distinctive corner material are recommended.
(ii) Façade openings and windows should be vertically proportioned, with a greater height than width.
40 (iii) Upper-floor windows should be enhanced with architectural details such as sills, molded surrounds, and lintels.
(iv) Window and balcony placement should be sensitive to the existing arrangement of windows and outdoor living spaces on adjoining properties.
b. Colors and Materials
(i) Projects should avoid the use of simulated materials. (ii) Exterior materials used should be consistent with or compliment the use of exterior materials in the neighborhood.
(iii) The colors and materials used on the exterior of a building should adhere to an appropriately varied palette.
(iv) Changes in color or materials should be used to differentiate between different components of a building, utilizing both primary and secondary materials. (v) Any accent materials should be used on all visible façades of the building, not only the front façade.
41 EXHIBIT B - Definitions
Staff Recommendations
§18.08.010 – General “A” Definitions
Apartment. An apartment, sometimes called flat, is a self-contained residential unit within a larger building containing five or more units. Each unit includes private amenities such as a kitchen, bathroom, and sleeping area, and may be rented or owned. Common facilities like laundry rooms, gyms, parking, and recreational areas are generally provided for residents. Apartments are often accessed through shared hallways and structurally share such elements as walls, floors, roofs, and common areas like staircases and elevators. “M” Definitions
Multiple-Family Dwellings. A structure or development, on a single lot, containing three or more dwelling units, each of which is for occupancy by one or more persons as a single housekeeping unit. (includes:. They include:
triplexes, (structures under one ownership with three dwelling units in the same structure), fourplexes (structures under one ownership with four dwelling units in the same structure), and apartments (five or more units under one ownership in a single structure or complex); and common ownership, attached unit projects including / condominiums with common driveways and amenities. Also includes factory-built, modular housing units and mobile homes/manufactured housing units when placed on permanent foundation systems. Does not include duplexes.
“R” Definitions
Rowhouse. A single-family attached dwelling which is attached to another dwelling, excluding accessory dwellings, and designed for or used exclusively for residential purposes of one family. Each dwelling is separately owned, located on a discrete parcel, and is attached to similar structures along a single parcel line in a linear arrangement and separated vertically by party walls. Each dwelling unit has a totally exposed front and rear wall used for direct groundlevel access to the outdoors. “S” Definitions
Single-Family Dwellings. A structure containing one dwelling unit located on a single parcel for occupancy by one housekeeping unit. Also includes factorybuilt, modular housing units, and mobile homes/manufactured housing when placed on permanent foundation systems.

Single-Family Dwellings, Attached. A dwelling attached to another dwelling, excluding accessory dwellings. Each dwelling is separately owned, located on a discrete parcel, and is joined to another dwelling along a single parcel line. Each dwelling is totally separated from the other by an unpierced wall extending from ground to roof. They include two units (duets or semi-detached homes) or three or more attached dwelling units, with each unit on a discrete parcel...

Single-Family Dwellings, Detached. A dwelling not attached to another dwelling, excluding an accessory dwelling unit. The dwelling is owned in fee and is located on an individual parcel.
“T” Definitions
Townhouse. A structure designed for or used exclusively for residential purposes of one family. The structure is attached to similar structures in a linear 42 arrangement and separated vertically by party walls. Each dwelling unit has a totally exposed front and rear wall used for direct ground-level access to the outdoors. Each townhouse could be located on a separate parcel or be part of a multi-family development.

EXHIBIT C
Corrections to Exhibit K adopted by City Council on March 18, 2025 Add missing text to sub-section 18.96.030.E.4.c
§18.96.030.AE.4 –
General
Provisions
Except as otherwise provided in this chapter, an Accessory Dwelling Unit (ADU) or a Junior Accessory Dwelling Unit (JADU) that meets all of the following specified
development standards shall be approved by the City:

4. Multiple detached ADUs, not to exceed:
a. Eight detached accessory dwelling units on a lot with an existing multi-family dwelling. However, the number of
accessory dwelling units shall not exceed the number of existing units on the lot.
b. Two detached accessory dwelling units on a lot with a proposed multi-family dwelling.
c. The ADUs must not exceed the allowed height in
Subsection 18.96.050.C and must have a minimum rear and side setbacks of four feet. If the existing multifamily dwelling has a rear or side setback of less than four feet, the existing multifamily dwelling will not be required to be modified to meet this setback.

EXHIBIT D
Corrections to Table 2-3 of Section 18.12.020 – Land Use Regulations and Allowable Uses regarding Two-Family Dwellings – Attached Only and Home Businesses.

Table 2-3
Allowed Uses and Permit
Requirements
Mixed Use Zones
Permit Requirements
P Permitted By-Right
CUP Conditional Use Permit (Chapter 18.88)
AUP Administrative Use Permit (Chapter 18.88)
TUP Temporary Use Term Permit (Chapter 18.94)
— Prohibited
Land Use
See Article 1 for land use definitions.

See Chapter 18.04 for unlisted uses.

MUC MUL MUH Specific Use
Regulations
Residential Uses
Two-Family Dwellings - Attached Only
Located on 1st floor CUP P CUP CUP
Located above 1st floor P P P
Transitional Housing — — —
Home Businesses HBP HBP HBP Section 18.48.100 110
Live-work Units CUP CUP CUP Not allowed on 1st floor
43 EXHIBIT E - Development Standards
Staff Recommendations
§18.10.030 – Development
Standards
E. Second Curb Cuts Prohibited. Except for projects with parking areas originally designed with more than one curb cut for ingress and egress or as set provided for herein, second curb cuts are generally not allowed. Accordingly, Ssingle-family homes are restricted to one curb cut, except for corner lots with Accessory Dwelling Units (ADUs) on corner lots under certain conditions, including where a second driveway may be allowed as long as it is proposed at least 25-feet away from the point of intersection of the two property lines fronting the parcel and from any other driveway. Second driveways shall incorporate permeable pavers that minimize runoff.

EXHIBIT F - Development Standards
Table 2-2
Development Standards for Residential Zones
Development
Feature
(minimum
unless
otherwise
indicated)
R-LD R-MD R-HD R-UHD Additional
Requirements
Setbacks1 and 2
Rear
1st Story
2nd Story
(see footnote 1
for structures
above 18 feet)
10 ft.
10 ft.
20 ft.
30 ft.
20 ft. 20 ft.

R-LD zone:

The 10-foot
rear setback
requires a
minimum of
750 700 sq. ft.
of usable rear
yard area; if
not,
development is
not allowed.

Open Space - Minimum sq. ft. of open space required for each dwelling unit. All open space areas shall be landscaped in compliance with Chapter 18.28
700 sq. ft.
in rear of
property,
usable and
open, no
permanent
hardscape. Or
500 sq ft or
50% of the
existing rear
yard,
whichever is
less restrictive 44
with ADUs. 1
NOTES:

1. Front and Side Setback Increase Over 18 22 Feet in Height For Single-Family Dwellings. Where a new structure or an addition to an existing single-family structure will exceed 18 22 feet in height, the required setback from the front and side property lines of the site shall be increased by one foot for each two feet of structure height in excess of 18 22 feet; the increased setbacks are to be imposed only with respect to that portion of the new structure or addition that exceeds 18 22 feet in height. Up to 50 percent of the proposed structure can utilize the single-story side setback for a structure; provided that the area where the addition will occur will not reduce air, light, and privacy to adjoining properties. The Commission, as part of the Design Review process, may allow more than 50 percent of the proposed structure to utilize the single-story setback if the proposal exhibits exceptional design.

2. Setbacks for Narrow Parcels. Side setbacks for existing, legally subdivided parcels which do not meet current minimum standards with respect to parcel width may be reduced to no less than 10 percent of the parcel width or three feet, whichever is greater. This provision applies only to portions of the structure under 18 22 feet in height. Where a new structure or an addition to an existing structure will exceed 18 22 feet in height, the required setback from each property line of the site shall be increased by one foot for each two feet of structure height in excess of 18 22 feet, the increased setbacks to be imposed only with respect to that portion of the new structure or addition that exceeds 18 22 feet in height.

EXHIBIT G – Service Stations
§18.48.180
Staff Recommendations
§18.48.180 – Service Stations
A. Applicability. The provisions in this section apply to all vehicle service stations where allowed.

B. Standards. A vehicle service station use shall comply with the regulations and restrictions applicable to the zone in which it is located and all of the following:

1. Parcel size. The minimum parcel size shall be 16,000 square feet.

2. Minimum street frontage. The minimum street frontage shall be 120 feet. If located on a corner, at least one street frontage shall measure at least 120 feet.

3. Allowed uses. Service Stations shall be allowed by Conditional Use Permit only in mixeduse zones along University Avenue between Donohoe Street and Bell Street and at the intersection of E. Bayshore Road and Pulgas Avenue. The primary use of a service station shall be the dispensing of motor fuels, lubricants, vehicle recharging, and the exchange of motor vehicle parts in kind. Limited / Incidental vehicle/equipment repair shall be limited to the hours of 7:00 a.m. to 7:00 p.m., daily. Such repair / service include air conditioning service, carburetor and fuel injection service, electrical service, radiator service, tune-up, lube, oil change, and smog check, as well as tires, batteries and accessories installation. 1 Previously adopted by City Council (ZTA23-001) on February 6, 2024 45 EXHIBIT H – Land Use Regulations and Allowable Uses
§18.12.020
Table 2-3
Allowed Uses and Permit
Requirements
Mixed Use Zones
Permit Requirements
P Permitted By-Right
CUP Conditional Use Permit (Chapter 18.88)
AUP Administrative Use Permit (Chapter 18.88)
TUP Temporary Use Term Permit (Chapter 18.94)
— Prohibited
Land Use
See Article 1 for land use definitions.

See Chapter 18.04 for unlisted uses.

MUC MUL MUH Specific Use
Regulations
Recreation, Education, and Public Assembly Uses
Schools, Public and Private CUP CUP CUP
Vehicle Rental, Sale and Service Uses
Vehicle/Equipment Rentals
Vehicle Washing — — —
Refueling/Service Stations (only on University
Avenue between Donohoe Street and Bell Street
and the intersection of E. Bayshore Road and
Pulgas Avenue)
CUP CUP CUP Section 18.48.180.B.3
• No incidental
repair/service
EXHIBIT I – 15-foot Front and 5-foot Side Setbacks in Residential Zones §18.10.030
Table 2-2
Development Standards for Residential Zones
Development
Feature
(minimum unless
otherwise indicated)
R-LD R-MD R-HD R-UHD Additional
Requirements
Setbacks1 and 2
Front
Living Area
Garage Face
10 ft.
23 ft.
20 15 ft. 15 ft. 20 15 ft.

Corner Vision
Triangle
12 ft. 12 ft. 12 ft. 12 ft.

Side/Street Side 5 ft. 10 5 ft. 10 5 ft./15 ft. 10 5 ft./15 ft.

EXHIBIT J – Criteria for Tree Removal
Staff Recommendations
§18.28.070 – Criteria for Tree
Removal
46 A Protected Tree may be removed under the following circumstances:

E. Removal is requested by a utility, public transportation agency, or other governmental agency due to a health or safety risk resulting from the tree's interference with existing or planned public infrastructure and preservation of the tree would add unreasonable cost to the project.

Based on such a request, a Tree Removal Permit may be processed without requiring the submittal of an Arborist Report.

EXHIBIT K – Enforcement
Staff Recommendations
§18.28.110 – Enforcement
A. Violations. Violation of a provision contained in this chapter is unlawful and a public nuisance. The Director may serve notice upon any person violating any provision of this chapter. Violators shall be subject to the provisions set forth in Chapter 1.118 18.118 - Enforcement.

EXHIBIT L - Definitions
§18.08.010
Staff Recommendations
§18.08.010 – General “H” Definitions
An accessory use of a dwelling residential parcel, conducted entirely within the dwelling parcel, and carried on by one or more persons, all of whom reside in on the dwelling parcel, and where no persons are employed other than domestic help and where the use is clearly incidental and secondary to the use of the dwelling parcel for residential purposes and does not change the character or adversely affect the uses allowed in the residential zone of which it is a part.

EXHIBIT M – Home Businesses (Home Occupation Permit)
§18.48.110
Staff Recommendations
§18.48.110 – Home Businesses
(Home Occupation Permit)
C. Standards. Home businesses are subject to the requirements of the base residential or mixed use zone where located, any conditions imposed on the Home Occupation Permit and all of the following standards:

1. A home business shall be conducted as an accessory use of a dwelling unit, conducted entirely within the dwelling unit or an accessory structure, and carried on by one or more persons, all of whom reside in the dwelling unit, and where no persons are employed other than domestic help;
47 2. A home business shall be clearly incidental and secondary to the use of the dwelling for residential purposes and shall not change the character of the dwelling or accessory structure or adversely affect the uses allowed in the residential or mixed use zone;

3. The home business shall be operated in a manner so as to not cause a nuisance (e.g., noise, vibrations, dust, odors, glare, debris, smoke, television or radio interference, heat, radiation, or other nuisances) detectable outside the dwelling or accessory structure or through common walls of an attached dwelling;

4. The appearance of the dwelling or any accessory structure shall not be altered so that the dwelling may be recognized as serving a nonresidential use (either by color, construction, dust, materials, odors, lighting, noise, signs, sounds, vibrations, etc. or that disturbs the peace). The existence of a home business shall not be apparent beyond the boundaries of the subject site;

5. There shall be no signs allowed other than the address for the main dwelling. No exterior signage shall identify the business. There shall be no other advertising using the home address, with the exception of advertising in the telephone directory or via the Internet. All advertising shall clearly state "by appointment only" if the residential address is used;

6. No more than 25 percent of the gross floor area of one floor of the residence or one room, whichever is less, shall be used for the purpose of home business. Use of space in a garage shall be preceded by approval of a planning permit allowing the garage conversion; or accessory structure is prohibited;

7. The use shall not involve the storage of hazardous, flammable, or combustible liquids or materials, other than those customarily found in or of greater intensity and/or duration of those customarily associated with a residence;

8. Customers of the home business are allowed at the residence only between the hours of 9:00 a.m. and 8:00 p.m.;

9. The entrance to the space devoted to the home business shall be from within the primary dwelling unit and there shall be no internal or external alterations to the existing dwelling that would provide an entrance other than the same of the entire dwelling unit;

10. The home business shall be restricted to the interior of the dwelling unit or accessory structure and shall not take place on external areas of the subject property; , the dwelling's garage, or in any accessory structure;

11. No more than 50 cubic feet of storage shall be devoted to the storage of inventory or products in any part of the dwelling or accessory structure. There shall be no storage of equipment or supplies within an accessory structure. Outdoor storage of any items related to the home business is prohibited;

12. No persons other than residents of the dwelling or domestic help shall work or report to work on the premises;

F. Findings for a Home Occupation Permit.

3. No business license shall be issued for a home business and no use shall be established as a home business for five business days after a Home Occupation Permit has been approved or while an appeal is pending.

G. Permit Limitations.

3. A new Home Occupation Permit and business license, whether for the same or a different home occupation conducted by a new resident, shall be obtained before conducting an allowed operating a permitted home business. Therefore, a Home Occupation Permit "does not run with the land.”

4. A change in the type of home business activity conducted by the resident requires a new Home Occupation Permit and business license.
48 EXHIBIT N - Temporary Use Permits
Chapter 18.94
Staff Recommendations
§18.94.050 – Allowed
Temporary Uses The following temporary uses are allowed on private property, subject to the issuance of a Temporary Use Permit, and only when conducted in compliance with the specified time limits and conditions of approval. To issue a No Minor Temporary Use Permit shall be issued if another temporary use has occurred on the subject property within the previous 30 days (whether by the same applicant or otherwise) notice should be given to surrounding property owners followed by a hearing:

B. Allowed Temporary Uses.

1. Amusement rides, arts and crafts exhibits, auctions, carnivals, circuses, concerts, fairs, farmer's markets, festivals, flea markets, food markets/events, outdoor
entertainment/sporting events, petting zoos, rodeos,
rummage sales (not garage or yard sales), and swap
meets limited to six 14 consecutive days or less within any 30-day period, or six seven two-day weekends,
within a 12-month period. When an annual plan is
submitted to and approved by the Director, the
frequency and duration of these special events may be
extended.

2. Outdoor display and sale events conducted by a retail business, including auto dealerships, holding a valid
business license, issued in compliance with Municipal
Code Chapter 5.04 may be allowed a maximum of six
outdoor sale events (excluding City-sponsored activities) in a year. An outdoor sale event shall be no longer than seven consecutive days in duration. When an annual
plan is submitted to and approved by the Director, the
frequency and duration of these special events may be
extended.

5. Major Temporary uses on the same lot shall be
separated by at least 30 days. Additional time shall be added in between Major Temporary Use Permits at the
discretion of the Director.
§18.94.060 – Application Filing
and Processing B. Types of Temporary Use Permits.

1. Minor Temporary Use Permit. Permit for use lasting
from one to six no more that 30 days. The days may be
consecutive.

2. Administrative Temporary Use Permit. Permit for use
lasting from seven to 30 days. The days maybe
consecutive.

3. Major Temporary Use Permit. Permit for use lasting from 31 to 365 days. The days maybe consecutive.
§18.94.070 – Director Review
A. Director Action. The Director may take action on a
Temporary Use Permit for a temporary use operated in
compliance with conditions of approval as follows: 49

1. A Minor Temporary Use Permit may be approved
administratively without notice or hearing.

2. An Administrative Temporary Use Permit may be
approved administratively by the Director, with
notice provided to abutting property owners.

3. A Major Temporary Use Permit may be approved after
notice and hearing to adjacent property owners by the
Director. The Director may defer action and refer the
application to the Commission for review and final
decision.
§18.94.110 – Post Decision
Procedures The procedures and requirements related to permit implementation and to appeals (Major Temporary Use Permits only) and revocation apply following the decision on a Temporary Use Permit application.

EXHIBIT O – Definitions
Chapter 18.08
Staff Recommendations
§18.08.010 – General “A” Definitions
Alcohol Sales.

Alcohol Sales (off-site-sale). Any establishment, such as a liquor store or convenience market, that sells, serves, or gives away alcoholic beverages in unopened containers for consumption off the premises and that is applying for or has obtained an ABC License Type 20 (off-sale beer and wine-package store) or License Type 21 (off-sale general-package store). The
establishment shall include any immediately adjacent area owned, leased, rented, or controlled by the licensee. Does not include an establishment selling alcoholic beverages as an accessory line of merchandise.

Alcohol Sales (off-site-sale), Accessory. Any establishment that sells, serves, or gives away alcoholic beverages for consumption off the premises and that is applying for or has obtained an ABC License Type 20 (off-sale beer and winepackage store) or License Type 21 (off-sale general-package store), where the sale of alcoholic beverages is accessory to the retail sale of goods and the display area for alcoholic beverages does not exceed 30 percent of the net floor area of the use.

Illustrative examples include drug stores, grocery stores, and supermarkets, but do not include convenience markets.

Alcohol Sales (on-site-sale). An establishment, such as a bar, tavern, or other drinking establishment, that has all of the following 50 characteristics:

1. Alcoholic beverages will be or are sold, served, or given away for consumption on the premises where sold, served, or given away; and

2. The establishment is applying for or has obtained an appropriate ABC License such as ABC License Type 48.;
and

3. The sale of alcoholic beverages is accessory to the retail sale of food products and the display area for alcoholic beverages does not exceed 30 percent of the net floor
area of the use. Illustrative examples include drug stores, grocery stores, and supermarkets, but do not include
convenience markets.

Alcohol Sales (on-site-sale), Incidental. An establishment which sells, serves, or gives away alcoholic beverages, as an incidental or ancillary activity, for consumption with a meal at a bona fide public eating establishment where the operator is applying for or has obtained an ABC License Type 47.
“E” Definitions
Bar, Lounge, and Nightclub / Drinking Establishment. An establishment selling or serving alcoholic beverages for consumption on the premises and holding or applying for a public premises license from the California State Department of Alcoholic Beverage Control (ABC). Persons under 21 years of age are not allowed to enter and remain on the premises. The establishment includes any immediately adjacent area that is owned, leased, rented, or controlled by the licensee.

Eating Establishment. A bona fide public eating place is a location that is regularly used for the serving of meals to guests for compensation and has suitable kitchen facilities. It must maintain a sanitary condition and comply with local health regulations. The establishment must provide an assortment of foods commonly ordered at various hours of the day, and guests must order and obtain a meal at the establishment during regular meal hours.

EXHIBIT P - Alcohol Sales
Chapter 18.48
Staff Recommendations
§18.48.040.A, 18.48.040.D.1,
and 18.48.040.E.1.d
A. Applicability. The provisions in this section apply to all alcohol sales uses whether for on-site (bars, nightclubs, and
establishments where consumption of alcoholic beverages is the primary use, but excluding incidental sale of beer and wine at bona 51 fide public eating establishments) or off-site consumption where allowed in compliance with all of the following standards.

D. Conditions of approval. The Review Authority may impose conditions upon the issuance of the permit it deems appropriate, necessary, and reasonable, under the circumstances, including, but not limited to, the following:

1. Approve the initial permit for a period not to exceed three years, with annual reviews required for the first two years;

2. Limitation upon the hours of the day during which alcoholic beverages can be sold;

3. Requirement for special trash collection service; and/or

4. Requirement for special security arrangements; provided however, the cost shall not impose an unreasonable
economic hardship upon the proprietor of the establishment.

E. Determinations of Public Convenience or Necessity (PCN).

Determinations within the jurisdiction of the Council in compliance with Section 23958.4 of the Business and Professions Code as to whether the public convenience or necessity (PCN) would be served by the issuance of an ABC license are delegated to the Commission.

d. To what extent is the sale of alcohol is essential to the primary purpose of the business? What percentage of
the business's sales is anticipated to be alcohol sales; EXHIBIT Q – Corrections and clarifications to Table 2-3 of Section 18.12.020 – Land Use Regulations and Allowable Uses regarding Alcohol Sales and Food Service Chapter 18.08
Table 2-3
Allowed Uses and Permit
Requirements
Mixed Use Zones
Permit Requirements
P Permitted By-Right
CUP Conditional Use Permit (Chapter 18.88)
AUP Administrative Use Permit (Chapter 18.88)
TUP Temporary Use Term Permit (Chapter 18.94)
— Prohibited
Land Use
See Article 1 for land use definitions.

See Chapter 18.04 for unlisted uses.

MUC MUL MUH Specific Use
Regulations
Retail Trade Uses
Alcohol Sales (off-site-sale) CUP CUP CUP Section 18.48.030 040
Alcohol Sales (off-site-sale), Accessory CUP CUP CUP Section 18.48.030 040 52
Alcohol Sales (on-site-sale) – Bars, Taverns,
etc.

CUP CUP CUP Section 18.48.030
040
Retail Sales P P P
Retail Sales (Used Merchandise) P P P Section 18.48.170 Retail Sales (Used Merchandise) -
Restricted
AUP AUP AUP Municipal Code
Chapter 5.40
Service Uses - General
Eating and Drinking Establishments
Food Service (no alcohol sales [bars,
lounges, or nightclubs], drive-through, fastfood, or late hours) P P P Incidental sale of
alcohol with meals in
eating
establishments
allowed
EXHIBIT R – Corrections and clarifications to Table 2-5 of Section 18.14.020 – Land Use Regulations and Allowable Uses regarding Alcohol Sales and Food Service Chapter 18.08
Table 2-5 Allowed Uses and Permit
Requirements
Commercial Zones Permit Requirements
P Permitted By-Right
CUP Conditional Use Permit (Chapter 18.88)
AUP Administrative Use Permit (Chapter 18.88)
TUP Temporary Use Term Permit (Chapter 18.94)
— Prohibited
Land Use
See Article 1 for land use definitions.

See Chapter 18.04 for unlisted uses.

C-G C-N C-0 Specific Use
Regulations
Retail Trade Uses
Alcohol Sales (off-site sale) CUP CUP CUP Section 18.48.030 Alcohol Sales (off-site sale), Accessory Uses CUP CUP CUP Section 18.48.030 Alcohol Sales (on-site sale) -Bars, Taverns,
etc.

CUP CUP CUP Section 18.48.030
Prescription Pharmacies, Medical Supplies P P P
Service Uses - General
Eating and Drinking Establishments
Food Service (no alcohol sales [bars,
lounges, or nightclubs], drive-through, fastfood, or late hours) P P P Incidental sale of
alcohol with meals in
eating
establishments
allowed
EXHIBIT S – Corrections and clarifications to Table 2-7 of Section 18.16.020 – Land Use Regulations and Allowable Uses regarding Alcohol Sales and Food Service.

Chapter 18.08
53 Table 2-7
Allowed Uses and Permit
Requirements
Special Purpose Zones
Permit Requirements
P Permitted By-Right
CUP Conditional Use Permit (Chapter 18.88)
AUP Administrative Use Permit (Chapter 18.88)
TUP Temporary Use Term Permit (Chapter 18.94)
— Prohibited
Land Use
See Article 1 for land use definitions.

See Chapter 18.04 for unlisted uses.

PI PR RM Specific Use
Regulations
Service Uses - General
Eating and Drinking Establishments
Food Service (no alcohol sales [bars,
lounges, or nightclubs], drive-through, fastfood, or late hours) AUP AUP __ Incidental sale of
alcohol with meals in
eating
establishments
allowed
54 ATTACHMENT 2
ORDINANCE NO.

AN ORDINANCE OF THE CITY COUNCIL

ARCHITECTURAL STANDARDS WITH NEW OBJECTIVE SITE AND ARCHITECTURAL DESIGN STANDARDS; 2) AMEND CHAPTER 18.08 DEFINITIONS TO AMEND SECTION

SERVICE STATIONS WITH CONDITIONAL USE PERMITS IN CERTAIN ROADWAY

18.08.010 – GENERAL, AND AMEND CHAPTER 18.48 TO AMEND SECTION 18.48.110

HOME BUSINESSES (HOME OCCUPATION PERMIT) TO ALLOW HOME OCCUPATIONS IN ACCESSORY STRUCTURES WITHIN RESIDENTIAL PROPERTIES AND TO CLARIFY 55

REGULATIONS FOR SPECIFIC LAD USES AND ACTIVITIES TO EXEMPT INCIDENTAL

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF EAST PALO ALTO DOES ORDAIN AS FOLLOWS:

SECTION 1. CHAPTER 18.10 AMENDED
Section 18.10.040 – Site Design and Architectural Standards is hereby repealed and replaced with Objective Site and Architectural Design Standards as shown in Exhibit “A”, attached hereto and incorporated herein by reference
SECTION 2. CHAPTER 18.08 AMENDED
Section 18.10.010 – General is hereby amended to add a definition for Apartment under “A” Definitions, to amend the definition of Multi-Family Dwellings under “M” Definitions, to add the definition of Rowhouse under “R” Definitions, to amend the definition of Single-Family Dwellings, Attached under “S” Definitions, and to amend the definitions of Townhouse and Two-Family Dwellings under “T” as shown in Exhibit “B”, attached hereto and incorporated herein by reference. 56
SECTION 3. CHAPTER 18.96 AMENDED
Sub-Sections 18.96.030.A.4 -General Provisions and 18.96.030.E.4.c are hereby amended as shown in Exhibit “C”, attached hereto and incorporated herein by reference.

Section 18.10.030 Table 2-2 is hereby amended as shown in Exhibit “F”, attached hereto and incorporated herein by reference, to align open space standards as previously adopted by Council.

SECTION 6. CHAPTER 18.48 AMENDED
Sub-Section 18.48.180.B.3 is hereby amended as shown in Exhibit “G”, and Sub-Section

Section 18.28.110 Enforcement is hereby amended as shown in Exhibit “K”, attached hereto and incorporated herein by reference.

SECTION 9. CHAPTER 18.08 DEFINITIONS AMENDED
Sections 18.08.010.”H” Definitions is hereby amended as shown in Exhibit “L”, attached hereto and incorporated herein by reference.

Sections 18.48.110 Home Occupations (Home Businesses) is hereby amended as shown in Exhibit “M”, attached hereto and incorporated herein by reference. 57 SECTION 10. CHAPTER 18.98 AMENDED
Section 18.94.050 Allowed Temporary Uses, Section 18.94.060 Application Filing and Processing, Section 18.94.070 Director Review, and 18.94.110 Post Decision Procedures are hereby amended as shown in Exhibit “N”, attached hereto and incorporated herein by reference.

SECTION 12. CHAPTER 18.48 AMENDED
Sub-Sections 18.48.040.A, 18.48.040.D.1, and 18.48.040.E.1.d are hereby amended as shown in Exhibit “P”, attached hereto and incorporated herein by reference.

SECTION 14. CALIFORNIA ENVIRONMENTAL QUALITY ACT.

SECTION 13. SEVERABILITY.

SECTION 14. EFFECTIVE DATE.
58 This Ordinance shall take effect and be in full force thirty (30) days after the date of its adoption.

SECTION 15. PUBLICATION.

The City Clerk is hereby directed to cause publication of this Ordinance as required by Government Code Section 36933.

INTRODUCED at regular City Council meetings held April 21, 2026, and May 5, 2026, and PASSED AND ADOPTED at a regular City Council meeting held on , 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

Weber Lincoln, Mayor
ATTEST: APPROVED AS TO FORM:

James Colin, City Clerk John D. Lê, City Attorney

EXHIBITS
Exhibit A – Objective Site and Architectural Design Guidelines Exhibit B – Definitions
Exhibit C – Corrections to previously approved “Exhibit K”.

Exhibit D – Corrections to Table 2-3.

Exhibit E – Development Standards on Second Curb Cuts.

Exhibit F - Table 2-2 Reconciliation of Private Open Space standards and Front and Side setback increase.

Exhibit G – Service Stations and associated uses. 59
Exhibit H - Table 2-3 Allowed Uses and Permit Requirements Exhibit I - 15-foot Front and 5-foot Side Setbacks in Residential Zones
Exhibit J – Criteria for Tree Removals.

Exhibit P – Alcohol Sales
Exhibit Q – Corrections to Table 2-3.

Exhibit R – Corrections to Table 2-5.

Exhibit S – Corrections to Table 2-7.
60 EXHIBIT A

18.10.040 - Site Design and Architectural Standards
A. Purpose.

B. Applicability.

C. Single-Family, Two-Family, Triplex, Fourplex and Townhouse

Figure 1. FRONT SETBACK CONDITION
Figure 2. GARAGE DOOR ALIGNMENT
61 2. General Site Design Guidelines
a. To the maximum extent possible, orientation of structures and windows should take advantage of natural light and wind patterns for natural heating and cooling. b. Driveways should be placed in a manner that avoids conflict with pedestrian access from the sidewalk.

4. Massing and Addition Standards
Intent: All new single-family, two-family, triplex, fourplex or townhouse buildings and residential additions should be designed to respect or complement the existing development pattern and massing as viewed from the street. An addition should be designed so that it appears to be part of the original structure.
a. Residential second/third-story additions shall employ at least two of the following building modulation strategies:
(i) Varied roof forms, including but not limited to changes in roof height, offsets, dormers, etc. (ii) Use of balconies, front porches, decks, overhangs, or covered patios. (iii) Projections, offsets, and/or recesses of the building wall at least 2 feet in depth, such as bay windows.
62 b. If the addition includes a large wall plane (longer than 20 feet), the plane shall incorporate at least two of the following architectural elements with bay window extensions, trellis features, recessed doors or windows, as follows:
a. A projection or recess with a minimum depth of 24 inches and a minimum width of 4 feet (e.g., bay window, wall offset)
b. A trellis or similar vertical feature covering at least 15% of the wall plane area. c. Door or window openings recessed a minimum of 4 inches from the wall surface d. Additional architectural detailing (e.g., material changes, trim, or reveals) that creates a minimum of one horizontal or vertical break per 20 feet of wall length c. All facades visible from a public right-of-way shall maintain a consistent design across the structure, incorporating the typical elements of the selected architectural style .

6. Privacy Standards
Intent: New residences and residential additions should be designed to preserve privacy, light, and air to adjoining properties to the extent feasible.
a. Second/third story additions shall step back from the front of the dwelling (the first story) by at least ten feet if the prevailing block condition is single-story (more than 60% of existing structures are single-story).
b. To preserve light and air for adjoining properties, where a new structure or an addition to an existing single-family structure will exceed 22 feet in height, the required setback from the side property lines of the site shall be increased by one foot for each two feet of structure height in excess of 22 feet; the increased setbacks are to be imposed only with respect to that portion of the new structure or addition that exceeds 22 feet in height. (Figure 3) 63 Figure 3. NEW ADDITIONS
c. Balconies that project outward from the structure (extending beyond the first-floor façade) shall be located a minimum of 20 feet from a shared rear or side property line. Inset balconies are exempted from this requirement. See Figure 4.

Figure 4. BALCONY SETBACKS
64 d. When a new structure or addition is located within five (5) feet of a side property line, upper floor windows on the building shall be oriented to avoid a direct line of sight into adjacent residential buildings or property (Figure 5):
(i) Windows shall be offset a minimum of three feet horizontally from windows of the nearest residential building on the adjacent property to maximize privacy. (ii) Windows on any floor to a non-habitable room such as a bathroom or closet may be excepted from this standard if both the following conditions are met:
a) The minimum windowsill height is six feet.
b) The window has frosted or privacy glass.
(iii) This standard shall be waived if there is a conflict with any Building Code requirements.

Figure 5. WINDOW LOCATION
e. A landscaped planter strip at least five feet in width shall be provided along the abutting interior property lines between a new structure or addition and any adjoining single-family residential units or single-family residential zoning district boundaries (except within the required front setback). The planter strip shall contain living plant material consisting of trees, shrubs, or hedges arranged to achieve a continuous visual screen. At the time of planting, materials shall be selected and spaced so that, with five years of installation, they form a screen at least six feet in height and at least 75 percent coverage when viewed horizontally from the adjacent single-family residential uses. All landscaping shall be installed prior to final inspection or occupancy and maintained in a healthy, living condition. Installation and maintenance shall be 65 in accordance with the Chapter 18.28 (Trees on Private Property), Chapter 18.10 (Residential Zones), Chapter 18.12 (Mixed Use Zones), Chapter 18.26 (Fences, Hedges and Walls), and Chapter 18.28 (Trees on Private Property) of the EPAMC.

7. Architectural Design Detail Standards
a. Materials
(i) All additions shall utilize materials and finishes that are consistent in type, color, texture, and architectural style with those of the style of the existing residential structure. Such materials and finishes shall be applied uniformly across all exterior facades of the addition. (ii) Buildings shall incorporate durable finish and/or accent materials, which include masonry, tile, stone, stucco, architectural grade wood, brick, and glass. (iii) All vents and electrical conduits shall be painted the same color as the adjacent surface. b. Roofs
(i) Rooflines and roofing materials shall match the architectural style of the existing residential structure in design, form, and appearance.
(ii) Use consistent, coordinated roofline forms and roofing materials across the design. Multiple rooflines and materials are permitted only when they are intentionally integrated into a cohesive architectural composition that demonstrates clear alignment, proportional relationships, and a unified material palette.
c. Garages
(i) Garages that are oriented toward the street (“front-loaded”) shall have a maximum width of 22 feet and shall comprise no more than 60% of the total façade width. The garage doors shall be located at least 23 feet from the public street. Standards for townhouse garages are provided in section iii below.
(ii) All attached or detached garages shall be set back at least six feet behind any living spaces. (Figure 6)
(iii) Tuck-under parking for townhouses shall follow the following standards: (Figure 7) a) Townhouse garages shall be accessed from an alley (or another internal road or driveway) and shall not exceed 75% of the townhouse frontage. b) A garage door shall not exceed 22 feet in width.
c) Garage doors shall be located a minimum of 2 feet from one another. d) For tuck-under parking along alleys, landscaping shall be located between garage doors and include a planting area or planter box with a minimum 12-inch length and width. 66 Figure 6. ATTACHED OR DETACHED GARAGES
Figure 7. TUCK-UNDER PARKING

3. Site Access Standards
Intent: Driveways should be placed in a manner to avoid conflict with pedestrian access from the sidewalk.
a. Driveways shall not exceed 26 feet in width (driveways serving regular truck traffic may not exceed 30 feet in width).
b. A clear pedestrian path of travel shall be provided between the public sidewalk and the primary building entrance(s). Pedestrian paths shall be clearly delineated with pavement materials and/or markings and signage.
c. Each project site shall be limited to one curb cut (including driveways, service streets and alleys) per 200 feet of public street frontage, unless otherwise required for emergency vehicle access. Two curb cuts are permitted for parking garage frontage. On public street frontages, curb cuts shall be located a minimum of 50 feet from street corners. 68 4. Site Access Guidelines
a. Pedestrian access from the street and the parking lot to the main door of the structure should be designed to avoid conflict with vehicular traffic. b. Common (shared) driveways between adjacent uses or sites are encouraged.

6. Parking Design Standards
a. Surface parking shall be located behind any buildings. If that is not feasible, surface parking may be located beside buildings if screened from the street with low walls and landscaping. (Figure 8)
b. Wherever possible, reciprocal access to parking areas between adjacent non-residential uses should be provided as long as each site provides its required parking, subject to the approval of the Director.
c. Surface parking lots shall be screened from adjacent publicly accessible streets as per landscaping standards in EPAMC 13.24.430.
d. Above grade structured parking structures facing a public street or publicly accessible open space shall have only the driveway(s) and the garage entry lobby visible, with the remaining façade length of the first story (ground floor) lined or wrapped with commercial or habitable uses with a minimum depth of 25 feet.
69 e. On upper levels, structured parking that comes to the façade edge shall be designed to resemble a non-parking use or be designed with artistic/architectural features and articulation by incorporating the following features on each street facing façade:
(i) Transparent or translucent windows covering a minimum of 30% of the façade; (ii) Horizontal or vertical articulation consistent with section D.10.c of Massing and Articulation Standards;
f. In order of preference (with the highest first), structured parking garages shall face and be accessed from:
(i) Alleyway
(ii) Private Street/Internal Street
(iii) Public Street, Side Street
(iv) Public Street, Corridor or Primary Street
(v) Public Open Space
g. All automated and stand-alone structured parking facilities shall submit a parking access plan that meets the following standards:
(i) Access control designed to accommodate peak demand without causing vehicle queuing in the public right-of-way
(ii) An appropriate number and location of entries and exits (iii) Adequate internal circulation
(iv) Signage for drivers and pedestrians
(v) On-site queuing
Figure 8. SURFACE PARKING SCREENING
70 7. Setback Area & Landscaping Design Standards
a. Front yard landscaping shall be provided consistent with landscaping requirements in EPAMC Sections 13.24.330, 17.06, and 18.30.090 and the City’s Urban Forest Master Plan. Setbacks shall be landscaped and/or hardscaped.
b. Existing mature, healthy trees shall be preserved in association with any remodeling or addition projects, as per the City’s Tree Protection Ordinance. c. Pervious or semi-pervious surfacing materials shall be used for pedestrian paths and driveways.
d. Underground parking shall not encroach under public streets or dedicated public parks and shall not be located under Public Utility Easements (PUEs). Underground parking, when fully below grade, may encroach into setbacks and below privately owned open space. e. Asphalt paving is not permitted in private or common usable open spaces. f. Setback areas in multifamily and mixed-use developments shall be landscaped according to the following standards:
(i) Building setbacks abutting ground floor residential uses shall be landscaped or include planter boxes for a minimum of 75% of the required setback area excluding areas for patios, porches, stoops, fire escapes, stair landings, and required walkways. For street frontage locations where the setback between the back-of-walk and building façade is 15 feet or greater, a minimum 1 tree per 40 linear feet of building frontage shall be planted within that setback area.
(ii) Building setbacks abutting ground floor storefront retail uses shall be landscaped and/or include planter boxes for a minimum of 25% of the setback area. (iii) Building setbacks abutting other ground floor non-residential uses (other than active uses such as restaurants or retail) shall be landscaped a minimum of 60% of the setback area.

Private Open Space shall meet the following standards (spaces may be provided that do not meet the standards below but they may not be counted toward the required Private Open Space):
(i) Floor to ceiling height shall have a minimum dimension of 9 feet. (ii) May be covered but not fully enclosed.
(iii) Be directly adjacent to and accessible from the dwelling unit it serves. (iv) Ground level private open space shall be screened or buffered from adjacent private or common open space and dwellings by landscaping, fencing, walls, trellises, or other screening elements.
b. Common Usable Open Spaces are outdoor open spaces in multi-family residential and residential mixed-use projects that are shared and accessible only to building residents and their visitors. Common open spaces may include courtyards, gardens, play areas, outdoor dining areas, recreational amenities, and rooftop open spaces. Spaces may be provided that do not meet the standards below, but they may not be counted toward the required 71 Common Usable Open Space. Common Usable Open Space shall meet the following standards:
(i) Shall be immediately adjacent to entrances, hallways, lobbies, or residential units. (ii) Shall be accessible to all residents.
(iii) A courtyard enclosed by three sides of a building shall have a minimum open-end width that is equal to or greater than 75% of the highest height of the adjoining faces. Any dimension shall be a minimum of 20 feet wide. (Figure 9) (iv) Fully enclosed courtyards shall have one minimum dimension that is equal to or greater than the highest height (up to 80 feet) of the adjoining facades. The second dimension shall be equal to or greater than 80% of the highest height of the adjoining facades. Any dimension shall be a minimum of 20 feet wide (Figure 10) (v) A minimum of 60% of the open space area shall be open to the sky and free of permanent weather protection or encroachments. Trellises and similar open-air features are permitted.
(vi) A minimum of 20% of the required open space area shall be planted with trees, ground cover, and/or shrubs.
(vii)Shall have permanent seating.

Figure 9. THREE-SIDE ENCLOSED COURTYARDS
72 Figure 10. FULLY ENCLOSED COURTYARDS

Buildings shall not exceed 250 feet in length in R-zones (R-LD, R-MD, R-HD, R-UHD). 73 b. Residential and mixed-use buildings greater than four stories in height shall reduce the massing of upper floors by a minimum of 10% of floor area for floors above the fourth (compared to the floor area of the ground floor).
c. For buildings three stories and taller, façades above the ground floor (or second floor if mixed-use) shall incorporate “breaks;” structural or design articulations that break large expanses down into smaller parts.
(i) The façade planes of residential-only and mixed-use residential buildings shall not exceed 100 feet in length without a façade break. For every 100 feet, provide a minimum of one large break, two medium breaks, or three minor breaks. (Figure 11 and Figure 12)
(ii) The size of the breaks in the façade plane should be sized depending on overall length of the façade and the number of breaks per facade:
a) Large Break. If one break is provided, the break should have a minimum width of 15 feet and a minimum depth of 10 feet.
b) Medium Break. If two breaks are provided, each break should have a minimum width of 10 feet and a minimum depth of 5 feet.
c) Minor Break. If three or more breaks are provided, each break should have a minimum width of 6 feet and a minimum depth of 3 feet.
(iii) These breaks shall continue through the ground floor façade for residential buildings, but do not need to do so for mixed-use buildings.

Figure 11. BREAKS FOR MIXED-USE
74 Figure 12. BREAKS FOR RESIDENTIAL ONLY
d. For residential and mixed-use facades, buildings shall establish a human-scaled rhythm with smaller individual building bay widths between 20 to 45 feet. This may be achieved with vertically oriented building modulation, facade articulation, and/or repeating vertically oriented patterns of fenestration.

12. Compatibility and Transition Standards
Intent: All new residential buildings or residential additions should be designed to respect or complement the existing development pattern and massing as viewed from the street, providing a transition when appropriate. An addition should be designed so that it appears to be part of the original structure.
75 a. Additions to existing multifamily residential structures shall be designed and constructed to match the architectural style and building form of the structure(s) to which they are added by using identical exterior materials, window proportions within +/-10% in height-to-width ratios, fenestration and roof form of the existing building. b. Windows, balconies, and similar openings shall be oriented to preserve privacy of individual units within the development. When a new structure or addition is located within five (5) feet of a side property line, upper floor windows on the building shall be oriented to avoid a direct line of sight into adjacent residential buildings or property by utilizing the following standards: (Figure 13)
(i) Windows shall be offset a minimum of three feet horizontally from windows of the nearest residential building on the adjacent property to maximize privacy. (ii) Windows on any floor to a non-habitable room such as a bathroom or closet may be excepted from this standard if both the following conditions are met:
a) The minimum windowsill height, if provided, is six feet. b) The window has frosted or privacy glass.
(iii) Balconies that project outward from the structure (extending beyond the first-floor façade) shall be located a minimum of 20 feet from a shared rear or side property line.

Inset balconies are exempted from this requirement. (Figure 14) (iv) The standards (i, ii, and iii) in this section shall be waived if there is a conflict with any Building Code requirements.
76 Figure 13. WINDOW LOCATION FOR PRIVACY
Figure 14. BALCONY SETBACK
77 c. A landscaped planter strip at least five feet in width shall be provided along the abutting interior property lines between a new structure or addition and any adjoining single-family residential units or single-family residential zoning district boundaries (except within the required front setback). Landscaping (trees, shrubs, or hedges) shall be planted within this strip, depending on the tree/plant species and canopy at maturity, to provide screening for adjacent single-family residential uses. All landscaping shall be installed in accordance with the EPAMC Chapters 18.28 (Trees on Private Property), 18.10 (Residential Zones), 18.12 (Mixed Use Zones), and 18.26 (Fences, Hedges and Walls), as applicable. d. When a building has a rear and/or interior side property line abutting a single-family residential zoned parcel (R-LD), starting above the third floor, each subsequent floor shall be stepped back by 10 feet for every two floors.
e. Vegetation used to screen views of a new residence or residential addition shall:
a. Achieve a minimum height of 6 feet within 3 years of planting; b. Provide at least 80% opacity year-round when viewed from adjacent properties; c. Be planted at intervals not exceeding 5 feet on center for shrubs or 15 feet on center for trees.
f. For a front or back building façade condition within the same site, building-to-building separation shall be a minimum of 45 feet for 4-story buildings or higher, a minimum of 35 feet for 3-story buildings and a minimum of 25 feet for 2-story buildings. g. For a side building façade condition within the same site, building-to-building separation shall be a minimum of 25 feet for 4-story buildings or higher, a minimum of 20 feet for 3- story buildings and a minimum of 15 feet for 2-story buildings. h. Building façades greater than 200 feet in length shall have at least two distinct façade compositions with at least two unique features of rhythm and pattern; material and color; modulation of building form; or façade articulation. Each of the compositions shall account for a minimum 20% of the total façade (Figure 15), and shall differ from the other in at least two of the following measurable ways:
a. Material type;
b. Color (minimum 15% difference in Light Reflectance Value (LRV)); 78 c. Plane offset of at least 12 inches;
d. Window pattern or spacing differing by at least 20%
Figure 15. FAÇADE COMPOSITION

14. Façade Design and Activation - General Ground Floor Standards a. All ground-floor building frontages facing public streets, public open spaces, and common open spaces shall include operable entrances and/or transparent windows serving interior spaces for to lobby use, living, working, neighborhood commercial, or other commercial spaces. Frontages facing service streets, alleys, rear lot lines, or private open space are not expected to have active uses.
b. Long blank walls (longer than 30 feet) without openings such as doors or windows are prohibited along facades facing public streets, public open space, or private streets with public access easements. 79
c. Parking structures shall be wrapped with ground floor uses along all street frontages. In lieu of ground floor uses, murals/art and landscaping are allowed on frontages facing service streets, alleys, rear lot lines, or private open spaces.

15. Façade Design and Activation - Residential Ground Floor Standards a. To provide adequate privacy for ground floor residential units in mixed-use zones, the closer the building is located to the back of sidewalk, the more elevated the ground-floor units shall be as follows:
(i) A building with a setback of 10 feet or less shall elevate units by at least 4.5 feet from the sidewalk level. (Figure 16). Alternatively, the units shall be provided with a canopied porch recessed or projected a minimum of two feet.
(ii) A building with a setback of 10 – 15 feet shall elevate units by at least 3 feet from the sidewalk level. (Figure 17). Alternatively, units shall be provided with a canopied porch recessed or projected a minimum of two feet.
(iii) A building with a setback greater than 15 feet does not need to elevate units. (Figure 18) Figure 16. GROUND FLOOR UNITS, LESS than 10 foot setback 80 Figure 17. GROUND FLOOR UNITS, 10-15 foot setback
Figure 18. GROUND FLOOR UNITS, more than 15 foot setback

16. Façade Design and Activation - Retail and Office Ground Floor Standards a. Ground floor retail and commercial storefronts shall have a minimum depth of 25 feet and a minimum floor-to-floor height of 16 feet.
b. On ground floor facades that face a public street, transparent glass windows shall be used that provide views into active interiors as follows: 81 Table 1: Glazing & Transparency Standards
Standard Storefront Office / Active NonResidential
Minimum Transparency
between 2 and 7.5 feet
65% 40%
Entrance Frequency Every 50 feet on average Every 80 feet on average

17. Façade Design and Activation - Upper Floor Façade Design Standards a. Balconies, where provided, shall utilize railing constructed of metal, glass, wood, or composite materials and shall match one of the primary exterior materials used on the building façade. Finishes shall match or fall within a 10% LRV range of the primary façade color scheme. .
b. Each facade exposed to public view shall include two of the following architectural features, landscaping, or art elements:
o Balconies with a minimum projection of 3 feet;
o Planter boxes with a minimum depth of 12 inches;
o Public art permanently affixed and covering at least 20 square feet; o Façade material changes covering at least 20% of the façade area. c. Blank end walls (without windows, porches, or balconies) shall be prohibited. Windows, balconies, or other modulation shall be provided for at least 10% of the façade area. d. Roof flashing, rain gutters, down spouts, vents, and other roof protrusions shall be screened from view or finished with materials and colors identical to the adjacent facade. e. All facades of a building facing a street or public space shall incorporate variations in massing and articulation such as horizontal and vertical offsets of at least 12 inches in depth.

18. Façade Design Guidelines
a. Building façades should be designed to have a distinct base, middle, and top. b. Ground-floor façades should be designed to give individual identity and visual interest to each individual establishment.
c. Commercial frontages should be broken into similar 20- to 35-foot wide modules. d. Where multiple tenant spaces are incorporated into a building, individual tenant spaces should be located within distinct building bays. This can be achieved by any of the following:
(i) Placing a column, pier, or pilaster between façade elements. (ii) Applying a vertical slot or recess between façade elements. (iii) Providing variation in plane along the building wall. (iv) Modulating the building wall by recessing storefront entrances or creating a niche for landscaping or for a pedestrian area.
(v) Varying wall materials.
e. One or more of the following elements should be used to articulate a building façade:
82 (i) Variation in the details for the top of a building, including cornice lines, parapets, eaves, brackets, and other detailing.
(ii) Variation in the details for the body, or middle, of the building, including awnings, overhangs, canopies, pilasters, columns, slots, decorative lighting, and window boxes. (iii) Variation in the details for the base of a building, including recessed entry areas, covered outdoor areas, and alcoves.
f. Façade details should appear integral to the architectural and structural design of the building rather than tacked onto the surface.

19. Architectural Design Detail Standards
a. Entries
(i) The main shared entry to the multi-family or mixed-use development shall be clearly delineated and identifiable, with a massing projection or recess with a minimum depth of 2 feet.
b. Windows and Balconies
(i) Windows facing a public right-of-way or publicly accessible open space shall be recessed a minimum of 2 inches to provide a “punched” recessed character or window trim shall be provided with a minimum of 2 inches in width and depth. (Figure 19) (ii) Windows that are flat or “flush” with the façade are prohibited unless applied to a portion of a building that is part of a recessed façade modulation that is recessed at least 4 inches. (Figure 20)
Figure 19. WINDOW DESIGN
83 Figure 20. WINDOWS IN RECESSED FAÇADE MODULATIONS
c. Materials
(i) At least two materials shall be used on any building frontage, in addition to glazing and railings.
(ii) A maximum of three primary exterior materials and finishes shall be used on any façade. Each material shall cover at least 20% of the façade area, excluding windows and doors. The same materials shall be consistently applied to all facades, with no façade excluding a material used on another facade by more than 30% of its coverage. (iii) Plywood, vinyl, T1-11, plastic (and plastic laminate), and fiberglass shall be prohibited as siding materials.
(iv) Materials shall continue around corners for at least two feet. (Figure 21) (v) Vinyl and plastic awnings are prohibited.

Figure 21. MATERIAL CORNER TREATMENT
84 d. Roofs
(i) Roof style and pitch shall be consistent with the style and pitch of other roofs within the development. . Roofs within a development shall have pitches within ±2:12 of each other and shall use the same roof form (e.g., gable, hip, flat) on at least 75% of buildings.

20. Architectural Design Detail Guidelines
a. Doors and Windows
(i) Main building entrances should be oriented toward the sidewalk and include architectural features that give them prominence. Treatments such as a change in height or a distinctive corner material are recommended.
(ii) Façade openings and windows should be vertically proportioned, with a greater height than width.
85 (iii) Upper-floor windows should be enhanced with architectural details such as sills, molded surrounds, and lintels.
(iv) Window and balcony placement should be sensitive to the existing arrangement of windows and outdoor living spaces on adjoining properties.
b. Colors and Materials
(i) Projects should avoid the use of simulated materials. (ii) Exterior materials used should be consistent with or compliment the use of exterior materials in the neighborhood.
(iii) The colors and materials used on the exterior of a building should adhere to an appropriately varied palette.
(iv) Changes in color or materials should be used to differentiate between different components of a building, utilizing both primary and secondary materials. (v) Any accent materials should be used on all visible façades of the building, not only the front façade.
86 EXHIBIT B - Definitions
Staff Recommendations
§18.08.010 – General “A” Definitions
Apartment. An apartment, sometimes called flat, is a self-contained residential unit within a larger building containing five or more units. Each unit includes private amenities such as a kitchen, bathroom, and sleeping area, and may be rented or owned. Common facilities like laundry rooms, gyms, parking, and recreational areas are generally provided for residents. Apartments are often accessed through shared hallways and structurally share such elements as walls, floors, roofs, and common areas like staircases and elevators. “M” Definitions
Multiple-Family Dwellings. A structure or development, on a single lot, containing three or more dwelling units, each of which is for occupancy by one or more persons as a single housekeeping unit. They include: triplexes (three dwelling units in the same structure), fourplexes (four dwelling units in the same structure), and apartments (five or more units in a single structure or complex and attached unit projects / condominiums with common driveways and amenities. Also includes factory-built, modular housing units and mobile homes/manufactured housing units when placed on permanent foundation systems. Does not include duplexes.
“R” Definitions
Rowhouse. A single-family attached dwelling which is attached to another dwelling, excluding accessory dwellings, and designed for or used exclusively for residential purposes of one family. Each dwelling is separately owned, located on a discrete parcel, and is attached to similar structures along a single parcel line in a linear arrangement and separated vertically by party walls. Each dwelling unit has a totally exposed front and rear wall used for direct groundlevel access to the outdoors. “S” Definitions
Single-Family Dwellings. A structure containing one dwelling unit located on a single parcel for occupancy by one housekeeping unit. Also includes factorybuilt, modular housing units, and mobile homes/manufactured housing when placed on permanent foundation systems.

Single-Family Dwellings, Detached. A dwelling not attached to another dwelling, excluding an accessory dwelling unit. The dwelling is owned in fee and is located on an individual parcel.
“T” Definitions
Townhouse. A structure designed for or used exclusively for residential purposes of one family. The structure is attached to similar structures in a linear arrangement and separated vertically by party walls. Each dwelling unit has a totally exposed front and rear wall used for direct ground-level access to the 87 outdoors. Each townhouse could be located on a separate parcel or be part of a multi-family development.

EXHIBIT C
Corrections to Exhibit K adopted by City Council on March 18, 2025 Add missing text to sub-section 18.96.030.E.4.c
§18.96.030.E.4 –
General
Provisions
Except as otherwise provided in this chapter, an Accessory Dwelling Unit (ADU) or a Junior Accessory Dwelling Unit (JADU) that meets all of the following specified
development standards shall be approved by the City:

EXHIBIT D
Corrections to Table 2-3 of Section 18.12.020 – Land Use Regulations and Allowable Uses regarding Two-Family Dwellings – Attached Only and Home Businesses.

See Chapter 18.04 for unlisted uses.

MUC MUL MUH Specific Use
Regulations
Residential Uses
Two-Family Dwellings - Attached Only
Located on 1st floor P CUP CUP
Located above 1st floor P P P
Transitional Housing — — —
Home Businesses HBP HBP HBP Section 18.48.110
Live-work Units CUP CUP CUP Not allowed on 1st floor
88 EXHIBIT E - Development Standards
Staff Recommendations
§18.10.030 – Development
Standards
E. Second Curb Cuts Prohibited. Except for projects with parking areas originally designed with more than one curb cut for ingress and egress or as provided for herein, second curb cuts are generally not allowed. Accordingly, single-family homes are restricted to one curb cut, except Accessory Dwelling Units (ADUs) on corner lots under certain conditions, including where a second driveway is proposed at least 25-feet away from the point of intersection of the two property lines fronting the parcel and from any other driveway. Second driveways shall incorporate permeable pavers that minimize runoff.

R-LD zone:

The 10-foot
rear setback
requires a
minimum of
700 sq. ft. of
usable rear
yard area; if
not,
development is
not allowed.

1. Front and Side Setback Increase Over 22 Feet in Height For Single-Family Dwellings.

Where a new structure or an addition to an existing single-family structure will exceed 22 feet in height, the required setback from the side property lines of the site shall be increased by one foot for each two feet of structure height in excess of 22 feet; the increased setbacks are to be imposed only with respect to that portion of the new structure or addition that exceeds 22 feet in height.

2. Setbacks for Narrow Parcels. Side setbacks for existing, legally subdivided parcels which do not meet current minimum standards with respect to parcel width may be reduced to no less than 10 percent of the parcel width or three feet, whichever is greater. This provision applies only to portions of the structure under 22 feet in height. Where a new structure or an addition to an existing structure will exceed 22 feet in height, the required setback from each property line of the site shall be increased by one foot for each two feet of structure height in excess of 22 feet, the increased setbacks to be imposed only with respect to that portion of the new structure or addition that exceeds 22 feet in height.

EXHIBIT G – Service Stations
§18.48.180
Staff Recommendations
§18.48.180 – Service Stations
A. Applicability. The provisions in this section apply to all vehicle service stations where allowed.

B. Standards. A vehicle service station use shall comply with the regulations and restrictions applicable to the zone in which it is located and all of the following:

1. Parcel size. The minimum parcel size shall be 16,000 square feet.

2. Minimum street frontage. The minimum street frontage shall be 120 feet. If located on a corner, at least one street frontage shall measure at least 120 feet.

EXHIBIT H – Land Use Regulations and Allowable Uses
§18.12.020
Table 2-3
Allowed Uses and Permit
Requirements
Mixed Use Zones
Permit Requirements
P Permitted By-Right
CUP Conditional Use Permit (Chapter 18.88) 90
AUP Administrative Use Permit (Chapter 18.88)
TUP Temporary Use Term Permit (Chapter 18.94)
— Prohibited
Land Use
See Article 1 for land use definitions.

See Chapter 18.04 for unlisted uses.

Corner Vision
Triangle
12 ft. 12 ft. 12 ft. 12 ft.

Side/Street Side 5 ft. 5 ft. 5 ft./15 ft. 5 ft./15 ft.

EXHIBIT J – Criteria for Tree Removal
Staff Recommendations
§18.28.070 – Criteria for Tree
Removal
A Protected Tree may be removed under the following circumstances:

Based on such a request, a Tree Removal Permit may be processed without requiring the submittal of an Arborist Report.
91 EXHIBIT K – Enforcement
Staff Recommendations
§18.28.110 – Enforcement
A. Violations. Violation of a provision contained in this chapter is unlawful and a public nuisance. The Director may serve notice upon any person violating any provision of this chapter. Violators shall be subject to the provisions set forth in Chapter 18.118 - Enforcement.

EXHIBIT L - Definitions
§18.08.010
Staff Recommendations
§18.08.010 – General “H” Definitions
An accessory use of a residential parcel, conducted entirely within the parcel, and carried on by one or more persons, all of whom reside in on the parcel, and where no persons are employed other than domestic help and where the use is clearly incidental and secondary to the use of the parcel for residential purposes and does not change the character or adversely affect the uses allowed in the residential zone of which it is a part.

2. A home business shall be clearly incidental and secondary to the use of the dwelling for residential purposes and shall not change the character of the dwelling or accessory structure or adversely affect the uses allowed in the residential or mixed use zone;

5. There shall be no signs allowed other than the address for the main dwelling. No exterior signage shall identify the business. There shall be no other advertising using the home 92 address, with the exception of advertising in the telephone directory or via the Internet. All advertising shall clearly state "by appointment only" if the residential address is used;

8. Customers of the home business are allowed at the residence only between the hours of 9:00 a.m. and 8:00 p.m.;

9. The home business shall be restricted to the interior of the dwelling unit or accessory structure and shall not take place on external areas of the subject property;

10. No more than 50 cubic feet of storage shall be devoted to the storage of inventory or products in any part of the dwelling or accessory structure. Outdoor storage of any items related to the home business is prohibited;

11. No persons other than residents of the dwelling or domestic help shall work or report to work on the premises;
F. Findings for a Home Occupation Permit.

G. Permit Limitations.

3. A new Home Occupation Permit and business license, whether for the same or a different home occupation conducted by a new resident, shall be obtained before operating a permitted home business. Therefore, a Home Occupation Permit "does not run with the land.”

4. A change in the type of home business activity conducted by the resident requires a new Home Occupation Permit and business license.

EXHIBIT N - Temporary Use Permits
Chapter 18.94
Staff Recommendations
§18.94.050 – Allowed
Temporary Uses The following temporary uses are allowed on private property, subject to the issuance of a Temporary Use Permit, and only when conducted in compliance with the specified time limits and conditions of approval. To issue a Minor Temporary Use Permit if another temporary use has occurred on the subject property within the previous 30 days (whether by the same applicant or otherwise) notice should be given to surrounding property owners followed by a hearing:

B. Allowed Temporary Uses.

1. Amusement rides, arts and crafts exhibits, auctions, carnivals, circuses, concerts, fairs, farmer's markets, festivals, flea markets, food markets/events, outdoor
entertainment/sporting events, petting zoos, rodeos, 93 rummage sales (not garage or yard sales), and swap
meets limited to 14 consecutive days or less within any 30-day period, or seven two-day weekends, within a 12-
month period. When an annual plan is submitted to and
approved by the Director, the frequency and duration of these special events may be extended.

1. Minor Temporary Use Permit. Permit for use lasting
no more than 30 days. The days may be consecutive.

2. Major Temporary Use Permit. Permit for use lasting from 31 to 365 days. The days maybe consecutive.
§18.94.070 – Director Review
A. Director Action. The Director may take action on a
Temporary Use Permit for a temporary use operated in
compliance with conditions of approval as follows:

1. A Minor Temporary Use Permit may be approved
administratively without notice or hearing.

2. A Major Temporary Use Permit may be approved after
notice and hearing to adjacent property owners by the
Director. The Director may defer action and refer the
application to the Commission for review and final
decision.
§18.94.110 – Post Decision
Procedures The procedures and requirements related to permit implementation and to appeals (Major Temporary Use Permits only) and revocation apply following the decision on a Temporary Use Permit application.

EXHIBIT O – Definitions
Chapter 18.08
Staff Recommendations
§18.08.010 – General “A” Definitions
Alcohol Sales. 94
Alcohol Sales (off-site-sale). Any establishment, such as a liquor store or convenience market, that sells, serves, or gives away alcoholic beverages in unopened containers for consumption off the premises and that is applying for or has obtained an ABC License Type 20 (off-sale beer and wine-package store) or License Type 21 (off-sale general-package store). The
establishment shall include any immediately adjacent area owned, leased, rented, or controlled by the licensee. Does not include an establishment selling alcoholic beverages as an accessory line of merchandise.

Illustrative examples include drug stores, grocery stores, and supermarkets, but do not include convenience markets.

Alcohol Sales (on-site-sale). An establishment, such as a bar, tavern, or other drinking establishment, that has all of the following characteristics:

1. Alcoholic beverages will be or are sold, served, or given away for consumption on the premises where sold, served, or given away; and

2. The establishment is applying for or has obtained an appropriate ABC License such as ABC License Type 48.

Alcohol Sales (on-site-sale), Incidental. An establishment which sells, serves, or gives away alcoholic beverages, as an incidental or ancillary activity, for consumption with a meal at a bona fide public eating establishment where the operator is applying for or has obtained an ABC License Type 47.
“E” Definitions
Bar, Lounge, and Nightclub / Drinking Establishment. An establishment selling or serving alcoholic beverages for consumption on the premises and holding or applying for a public premises license from the California State Department of 95 Alcoholic Beverage Control (ABC). Persons under 21 years of age are not allowed to enter and remain on the premises. The establishment includes any immediately adjacent area that is owned, leased, rented, or controlled by the licensee.

EXHIBIT P - Alcohol Sales
Chapter 18.48
Staff Recommendations
§18.48.040.A, 18.48.040.D.1,
and 18.48.040.E.1.d
A. Applicability. The provisions in this section apply to all alcohol sales uses whether for on-site (bars, nightclubs, and
establishments where consumption of alcoholic beverages is the primary use, but excluding incidental sale of beer and wine at bona fide public eating establishments) or off-site consumption where allowed in compliance with all of the following standards.

1. Approve the permit with annual reviews required for the first two years;

2. Limitation upon the hours of the day during which alcoholic beverages can be sold;

3. Requirement for special trash collection service; and/or

4. Requirement for special security arrangements; provided however, the cost shall not impose an unreasonable
economic hardship upon the proprietor of the establishment.

E. Determinations of Public Convenience or Necessity (PCN).

1. Application and hearing. The Commission shall conduct a public hearing upon an application for a determination of public convenience or necessity. The Commission shall
consider all of the following:
96 d. To what extent is the sale of alcohol essential to the primary purpose of the business? What percentage of
the business's sales is anticipated to be alcohol sales; EXHIBIT Q – Corrections and clarifications to Table 2-3 of Section 18.12.020 – Land Use Regulations and Allowable Uses regarding Alcohol Sales and Food Service Chapter 18.08
Table 2-3
Allowed Uses and Permit
Requirements
Mixed Use Zones
Permit Requirements
P Permitted By-Right
CUP Conditional Use Permit (Chapter 18.88)
AUP Administrative Use Permit (Chapter 18.88)
TUP Temporary Use Term Permit (Chapter 18.94)
— Prohibited
Land Use
See Article 1 for land use definitions.

See Chapter 18.04 for unlisted uses.

MUC MUL MUH Specific Use
Regulations
Retail Trade Uses
Alcohol Sales (off-site-sale) CUP CUP CUP Section 18.48.040 Alcohol Sales (off-site-sale), Accessory CUP CUP CUP Section 18.48.040 Alcohol Sales (on-site-sale) – Bars, Taverns,
etc.

CUP CUP CUP Section 18.48.040
Retail Sales P P P
Retail Sales (Used Merchandise) P P P Section 18.48.170 Retail Sales (Used Merchandise) -
Restricted
AUP AUP AUP Municipal Code
Chapter 5.40
Service Uses - General
Eating and Drinking Establishments
Food Service (no alcohol sales [bars,
lounges, or nightclubs], drive-through, fastfood, or late hours) P P P Incidental sale of
alcohol with meals in
eating
establishments
allowed
EXHIBIT R – Corrections and clarifications to Table 2-5 of Section 18.14.020 – Land Use Regulations and Allowable Uses regarding Alcohol Sales and Food Service Chapter 18.08
Table 2-5 Allowed Uses and Permit
Requirements
Commercial Zones Permit Requirements
P Permitted By-Right
CUP Conditional Use Permit (Chapter 18.88)
AUP Administrative Use Permit (Chapter 18.88)
TUP Temporary Use Term Permit (Chapter 18.94)
— Prohibited
Land Use
See Article 1 for land use definitions.

See Chapter 18.04 for unlisted uses.

C-G C-N C-0 Specific Use
Regulations
Retail Trade Uses 97
Alcohol Sales (off-site sale) CUP CUP CUP Section 18.48.030 Alcohol Sales (off-site sale), Accessory Uses CUP CUP CUP Section 18.48.030 Alcohol Sales (on-site sale) -Bars, Taverns,
etc.

Chapter 18.08
Table 2-7
Allowed Uses and Permit
Requirements
Special Purpose Zones
Permit Requirements
P Permitted By-Right
CUP Conditional Use Permit (Chapter 18.88)
AUP Administrative Use Permit (Chapter 18.88)
TUP Temporary Use Term Permit (Chapter 18.94)
— Prohibited
Land Use
See Article 1 for land use definitions.

See Chapter 18.04 for unlisted uses.

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: June 2, 2026
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: James Colin, City Clerk
SUBJECT: Pride Month Proclamation
Recommendation
Present the proclamation for Pride Month.

Attachments

1. Proclamation
99 PROCLAMATION OF THE CITY OF EAST PALO ALTO

CELEBRATING PRIDE MONTH
WHEREAS, the City Council of the City of East Palo Alto recognizes and proclaims the month of June 2026 as Lesbian, Gay, Bisexual, Transgender and Queer (LGBTQ) “Pride Month” throughout the City of East Palo Alto; and WHEREAS, East Palo Alto joins the County of San Mateo to observe Pride Month with a Progress Pride flag raising ceremony to honor the history of the LGBTQ liberation movement and to support the rights of all citizens to experience equality and freedom from discrimination; and
WHEREAS, the Progress Pride flag is widely recognized as a symbol of pride, inclusion, and support for social movements that advocate for LGBTQ people in society; and
WHEREAS, all human beings are born free and equal in dignity and rights.

LGBTQ individuals have had immeasurable impact to the cultural, civic and economic successes of our country; and
WHEREAS, East Palo Alto is committed to supporting visibility, dignity and equality for LGBTQ people in our diverse community; and WHEREAS, while society at large increasingly supports LGBTQ equality, it is essential to acknowledge that the need for education and awareness remains vital to end discrimination and prejudice; and
WHEREAS, this nation was founded on the principle that every individual has infinite dignity and worth, and the City Council calls upon the people of this municipality to embrace this principle and work to eliminate prejudice everywhere it exists; and WHEREAS, celebrating Pride Month influences awareness and provides support and advocacy for San Mateo County’s LGBTQ community, and is an opportunity to take action and engage in dialogue to strengthen alliances, build acceptance and advance equal rights.

NOW, THEREFORE BE IT RESOLVED that City Council of the City of East Palo Alto herby proclaims the month of June 2026 as Pride Month in support of the LGBTQ community.

June 2, 2026
Webster Lincoln
Mayor
100
CONSENT ITEM 3.3

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: June 2, 2026
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: James Colin, City Clerk
SUBJECT: Juneteenth Proclamation
Recommendation
Present the proclamation for Juneteenth.

Attachments

1. Proclamation
101

PROCLAMATION OF THE CITY OF EAST PALO ALTO
DECLARING JUNE 19, 2026, AS JUNETEENTH NATIONAL

FREEDOM DAY
WHEREAS, on September 22, 1862, President Abraham Lincoln issued the Emancipation Proclamation, officially ending slavery, changing the status of more than 3.5 million enslaved African Americans in the Confederate States of America; and
WHEREAS, the news of General Lee’s surrender moved slowly, and reached Texas on June 19, 1865, when General Gordon Granger and his troops traveled to Galveston, Texas to announce: “The people of Texas are informed that, in accordance with a proclamation from the Executive of the United States, all slaves are free;” and
WHEREAS, in remembrance and celebration of the June 19, 1865, announcement of the abolition of slavery we celebrate “Juneteenth,” also known as "Emancipation Day" or "Freedom Day" as the true anniversary and oldest known celebration commemorating the end of slavery in the United States; and
WHEREAS, Juneteenth observes an important milestone in the East Palo Alto's long march towards equality; a reminder of the great contributions African Americans have made as free citizens of our nation, as well as the injustices they suffered as slaves and the descendants thereof; and the courage of our forebears of all races and creeds who gave their lives to the fight against slavery and inequality; and
WHEREAS, throughout history there has been civil uprising due to continued systematic injustices on African Americans and in support of the Black Lives Matter movement along with support to BIPOC persons, we must stand in solidarity with those who are fighting for justice and human rights; and acknowledge that the struggle for equality continues.

NOW THEREFORE, BE IT RESOLVED THAT THE CITY COUNCIL OF EAST PALO ALTO HEREBY proclaim June 19, 2026, as “Juneteenth National Freedom Day” and encourage the community to unite in solidarity and continue to fight for justice.

Date: June 2, 2026

Webster Lincoln, Mayor
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CONSENT ITEM 3.4
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EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: June 2, 2026
TO: Honorable Mayor and Members of the City Council
VIA: John D. Lê, City Attorney
SUBJECT: Consent to Conflict Waiver
Recommendation
Adopt a resolution authorizing the City Attorney to execute a consent letter agreeing to a conflict waiver for Goldfarb & Lipman LLP with regards to their representation of Frolic Community regarding the development of housing cooperatives in the City, including 801 Donohoe Street.

Alignment with City Council Strategic Plan
Priority No. 3: Increase Organizational Effectiveness and Efficiency Background
Goldfarb & Lipman LLP advised the City Attorney of a potential conflict of interest of Goldfarb & Lipman arising from Goldfarb & Lipman’s representation of Frolic Community, a Washington corporation (“Frolic”), with activities regarding the development of housing cooperatives in the City, including 801 Donohoe Street (“Property”). The Properties in the City must obtain local entitlements prior to the development of any proposed housing cooperative. Goldfarb & Lipman LLP would advise Frolic regarding the entitlement and permitting process.

Goldfarb & Lipman LLP has represented and continue to represent the City in connection with a number of matters, including development projects, drafting local ordinances, land use, and affordable housing matters.

Frolic has expressed willingness to waive the conflict so that Goldfarb & Lipman can represent it in the entitlement process for the housing cooperatives. Goldfarb & Lipman would not represent the City in this project.

Analysis
103
CONSENT ITEM 3.4
990099\10\5011983.1
The Rules of Professional Responsibility require Goldfarb & Lipman LLP to obtain the informed written consent of both Frolic and the City in order to represent Frolic in this matter due to its existing relationship with the City. Goldfarb & Lipman LLP prepared a letter describing the potential for a conflict of interest. The City Attorney has reviewed the letter, and potential consequences of waiving the conflict and, has concluded that the potential for a conflict of interest is remote, and that Goldfarb & Lipman’s representation of Frolic in this matter will not have a detrimental impact on the City. The City Attorney recommends that the City Council waive the conflict in this instance by authorizing the City Attorney to execute a conflict waiver letter..

Alternative
Direct the City Attorney to refuse to waive the conflict in which event Goldfarb & Lipman would not represent either the Frolic with regard to the entitlement of the housing cooperative projects within the City.

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.

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.

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

Analysis of Levine Act Compliance: Not applicable.

Attachments

1. Conflict & Joint Representation Letter

2. Resolution
104
May 27, 2026

via email and u.s. mail
John Lê
City Attorney
City of East Palo Alto
2415 University Avenue, 2nd Floor
East Palo Alto, CA 94303
Tamara Knox
Co-Founder and CEO
Frolic Community
911 E Pike St, Suite 206
Seattle, WA 98122
Re: Consents to Potential Conflict of Interest
Dear Mr. Lê and Ms. Knox:

We write this letter regarding a request by Frolic Community, a Washington corporation ("Frolic") to represent it in connection with the proposed development of housing cooperatives in the City, including at 801 Donohoe Street, East Palo Alto, California (the "Properties"). Specifically, the Properties are regulated by the City's local ordinances regulating certain entitlement and development permit requirements applicable to the Properties. As part of the development of cooperatives, Frolic will have to seek and obtain permits from the City. Goldfarb & Lipman will assist Frolic in interpreting applicable local ordinances and state statutes and prepare application materials in order to process the entitlement and permit applications necessary for the development of the cooperatives (the "Entitlement Process"). Goldfarb & Lipman LLP currently represents the City of East Palo Alto (the "City"), advising on development projects, drafting local ordinances, land use, and affordable housing matters, but does not represent the City with regards to the Entitlement Process for the Properties.

The specific purpose of this letter is to advise you of a potential conflict of interest of Goldfarb & Lipman due to the existing and continued relationship that Goldfarb & Lipman has with the City and the proposed relationship that Goldfarb & Lipman has with Frolic. To undertake this representation, we are required to (1) disclose in writing our existing relationship with each of you, and (2) obtain the informed written consent of each of you to such potential conflict of interest, as described in this letter.. We believe that we will be able to provide competent and diligent representation to Frolic in this matter.
105
I. Existing Relationships.

The City is an existing client of Goldfarb & Lipman. We have assisted the City with development projects, drafting local ordinances, land use, and affordable housing matters.

II. Potential Conflict of Interest
While we are unaware of any current conflict of interest created by our existing relationships described in Section I above, as attorneys, we are governed by specific rules relating to our representation of clients when potential conflicts of interest exist. We must disclose certain information, and obtain the informed written consents of each of you to represent each of you in connection with the Planning Review as described in this letter, in accordance with Rules 1.1, 1.4,

1.6, 1.7, 1.8.2., 1.9 and 1.10 of the Rules of Professional Conduct of the State Bar of California (the "CRPC").

Our representation of Frolic in connection with the Entitlement Process could potentially create a conflict of interest for Goldfarb & Lipman if we have or become aware of information regarding one of you that is relevant to the Entitlement Process which would have an adverse effect on the other party. At this time, we do not believe that there is an actual conflict of interest for Goldfarb & Lipman, and we believe that we can competently represent Frolic in the Entitlement Process and still maintain our independent judgement and duty of loyalty to each of you in unrelated matters. In addition, we do not believe that we have obtained any confidential information from the City which is material to our proposed representation of Frolic, or from Frolic which is material to our continued representation of the City.

However, if an actual conflict should arise related to the Entitlement Process in which: (i) the interest of Frolic is now adverse to the interest of City, that would affect our independent judgment and our duty of loyalty to each of you in the unrelated matters; (ii) the issue of dispute in this Entitlement Process is substantially related to the same issue in which we have represented either of you in other matters; or (iii) we have obtained any confidential information from the City that is material to our representation of Frolic, or any confidential information from Frolic that is material to our representation of the City, we would need to determine if we could continue to represent Frolic in the Entitlement Process. In reaching our decision, we would first need to determine if we could competently continue such representation, notwithstanding the adversity, and after such determination, we would further need to obtain the informed written consent of each of you.

III. Informed Written Consent
You should thoroughly review and consider the matters discussed in this letter, and consider seeking independent counsel before providing your consent. If, after such review, each of you consents to Goldfarb & Lipman representing each of you in the manner outlined above, please sign and return the attached consent form (i) acknowledging that you have been advised of Goldfarb & Lipman's past and continuing relationships with each of you; (ii) acknowledging that you have been advised to Rules 1.1, 1.4, 1.6, 1.7, 1.8.2., 1.9 and 1.10 and the potential conflict of interest associated with our representation of Frolic in relation to the Entitlement Process; and (iii) that 106
990099\10\5011961.1
you nevertheless consent to our representation of Frolic in connection with the Entitlement Process.

If you have any questions regarding this letter or our representation of each of you, please call us before signing and returning the Consent attached to this letter.

Sincerely,
KAREN M. TIEDEMANN
107
990099\10\5011961.1

CONSENT
Goldfarb & Lipman has explained to each of you: (i) Goldfarb & Lipman's past and continuing relationships with each of you; (ii) CRPC Rules 1.1, 1.4, 1.6, 1.7, 1.8.2., 1.9 and 1.10 and the potential conflict of interest in relation to Goldfarb & Lipman's proposed representation of Frolic in connection with the Entitlement Process and the possible consequences of this conflict; and (iii) and the consequences of any actual conflicts that may arise. The undersigned nevertheless consent to Goldfarb & Lipman's representation of Frolic as described in this letter.

We understand that we have the right to seek independent counsel before signing this consent or at any future time.

Dated: ________________ CITY OF EAST PALO ALTO
By: ____________________________
John D. Lê, City Attorney
Dated: ________________ FROLIC COMMUNITY
By: ____________________________________
Tamara Knox, Co-Founder and Chief
Executive Officer
108
Resolution No. XX-2024 1 of 2
990099\10\5012002.1
RESOLUTION NO. XX– 2026

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO

AUTHORIZING THE CITY ATTORNEY TO EXECUTE A CONSENT LETTER AGREEING TO

THE REPRESENTATION BY GOLDFARB & LIPMAN LLP OF FROLIC COMMUNITY,

REGARDING HOUSING COOPERATIVE DEVELOPMENT
WHEREAS, Goldfarb & Lipman LLP advised the City Attorney of a potential conflict of interest of Goldfarb & Lipman related to its representation of Frolic Community (“Frolic”) in connection with activities regarding the development of housing cooperatives in the City, including that certain real property at 801 Donohoe Street, in East Palo Alto, CA; and WHEREAS, the City is an existing client of Goldfarb & Lipman LLP. They have represented and continue to represent the City in several matters regarding development projects, drafting local ordinances, land use, and affordable housing matters; and WHEREAS, Frolic is a proposed new client of Goldfarb & Lipman LLP; and WHEREAS, the Rules of Professional Responsibility require Goldfarb & Lipman LLP to obtain the informed written consent of both Frolic and the City in order to represent an adverse party; and WHEREAS, Goldfarb & Lipman prepared a letter describing the potential for a conflict to arise and request for consent to represent Frolic; and
WHEREAS, the City Attorney has reviewed the letter, and recommends approving the consent letter as it will assist the parties in developing affordable housing and the City is separately represented.

The City Attorney recommends that the City Council agree to waiver of the conflict

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. Consents to the representation of Frolic by Goldfarb & Lipman LLP;

3. Authorizes the City Attorney to execute a consent letter and any documentation necessary to effectuate this resolution; and

4. 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 ____ day of June 2026, by the following vote:

AYES:
109
Resolution No. XX-2024 2 of 2
990099\10\5012002.1
NOES:

ABSENT:

ABSTAIN:

Webster Lincoln, Mayor
ATTEST: APPROVED AS TO FORM:

James Colin, City Clerk John D. Lê, City Attorney
110
CONSENT ITEM 3.5

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: June 2, 2026
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 the May 19, 2026, City Council Meeting Minutes.

Attachments

1. May 19, 2026, Minutes
111

EAST PALO ALTO CITY COUNCIL

REGULAR SESSION MINUTES
Tuesday, May 19, 2026, 6:00 PM
EPA Government Center
2415 University Avenue, First Floor
East Palo Alto, CA 94303

1. CALL TO ORDER AND ROLL CALL
Council Member Barragan called the meeting to order at 6:01 PM, presiding in the absence of Mayor Lincoln and Vice Mayor Abrica. City Clerk James Colin confirmed a quorum was present.

Attendee Name Title Status Arrived
Webster Lincoln Mayor Late
(Remote)
Ruben Abrica Vice Mayor Absent
Carlos Romero Councilmember Present
Mark Dinan Councilmember Present
Martha Barragan Councilmember Present
(Presiding)

2. APPROVAL OF THE AGENDA
Motion: Council Member Dinan moved, Council Member Romero seconded, to approve the agenda. Motion carried 3-0.

3. APPROVAL OF CONSENT CALENDAR
No items were pulled. No public comments.

Motion: Council Member Romero moved, Council Member Dinan seconded, to approve the Consent Calendar (Items 3.1 through 3.6). Motion carried 3-0 (Ayes: Barragan, Dinan, Romero).

4. CLOSED SESSION
No closed session was held.

5. PUBLIC COMMENT
Two speakers addressed the Council. Gail Dixon requested an additional traffic sign near Tradewind Apartments following recent street improvements. Mario congratulated council members who supported the camera program and recognized staff work at a park pond.

6. ADJOURN CITY COUNCIL REGULAR MEETING TO THE EAST PALO ALTO

SANITARY DISTRICT BOARD MEETING
Council Member Barragan adjourned the City Council Regular Meeting and convened the EPASD Board Meeting, assuming the chair by consensus in the absence of the Board President and Vice President.
112

7. EPASD PUBLIC COMMENT
Mario provided public comment.

8. APPROVAL OF EPASD CONSENT CALENDAR

8.1 EPASD Cash Disbursement Report for March 2026
Council Member Romero requested that future EPASD reporting include quarterly budget-toactual comparisons given the level of public scrutiny the district has received. Finance Director Oku and City Manager Gaines agreed to discuss a framework and return to Council for direction.

Motion: Council Member Romero moved, Council Member Dinan seconded, to approve the EPASD Cash Disbursement Report for the period ending March 31, 2026. Motion carried 3-0.

9. EPASD BOARD MEETING INFORMATIONAL REPORTS
No informational reports were presented.

10. ADJOURN EAST PALO ALTO SANITARY DISTRICT BOARD MEETING AND

RECONVENE CITY COUNCIL REGULAR MEETING
The EPASD Board Meeting was adjourned and the City Council Regular Meeting was reconvened.

11. INFORMATIONAL REPORTS
No informational reports were presented.

12. SPECIAL PRESENTATIONS

12.1 101 Corridor Connect Program Update
Marissa Mathias, Senior Transportation Planner, San Mateo County Transportation Authority (SMCTA), presented on the 101 Corridor Connect Program. East Palo Alto priority projects include the University Avenue Grand Corridor (Phases 1 and 2), Pulgas Avenue, Willow Road, Newbridge Street, Saratoga Avenue, East Bayshore Road, Donahoe Street, and Bayshore Road.

Gail Dixon provided public comments.

SMCTA has set aside $4 million in a mini grant program for planning and conceptual design of priority projects. Grants are up to $750,000 per single-jurisdiction project ($1 million for multijurisdictional), with no match required. Applications are due July 2026; awards expected August 2026.

Action: Council directed Public Works Director Javed to develop a grant application. No formal vote taken.

13. PUBLIC HEARINGS

13.1 Comprehensive Fee Schedule Update
113
Finance Director Oku presented the annual administrative fee schedule update. Proposed adjustments: User and Regulatory Fees increased 2.5% (CPI-based); Development Impact Fees increased 2.7% (Construction Cost Index). No new fee categories were created.

Council discussed the BMR Monthly Monitoring Fee ($129/unit, approximately $1,548/year).

Council Member Dinan expressed concern about the cost relative to comparable jurisdictions.

Staff clarified monitoring covers deed restriction compliance beyond income verification. City Manager Gaines noted the monitoring contract expires October 2026 and suggested an RFP at that time. Council agreed to freeze the BMR fee at its current level pending contract review.

Gail Dixon provided public comment.

Motion: Council Member Romero moved, Council Member Dinan seconded, to approve the Comprehensive Fee Schedule with the BMR Monthly Monitoring Fee held at its current rate rather than receiving the 2.5% adjustment. Motion carried 3-0.

13.2 Fiscal Year 2026-27 Proposed Budget Session Hearing No. 2 Finance Director Oku introduced the session. The May 12 hearing covered Community & Economic Development, Police, and City Manager's Office. This session covered the remaining departments. The overall budget reflects a projected $4.7 million General Fund deficit.

The following departments presented on their budgets:
- City Attorney's Office
- City Clerk's Office and City Council
- Finance Department
- Public Works Department
- EPASD Budget Overview
- Capital Improvement Program (CIP) — Two-Year Update
Action: EPASD budget to be agendized for further discussion at the June 2, 2026, City Council meeting.

14. POLICY AND ACTION
No policy and action items were heard.

15. COUNCIL REPORTS
No council reports were presented.

16. ADJOURNMENT
The meeting was adjourned at 9:29 PM.
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CONSENT ITEM 3.6

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: June 2, 2026
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: James Colin, City Clerk
SUBJECT: Mr. Mancini Proclamation
Recommendation
Present the proclamation.

Attachments

1. Proclamation
115

PROCLAMATION OF THE CITY OF EAST PALO ALTO

HONORING PRINCIPAL MICHAEL MANCINI
UPON HIS RETIREMENT AFTER 30 YEARS OF SERVICE

AT REDEEMER ELEMENTARY SCHOOL, REDWOOD CITY
WHEREAS, Principal Michael Mancini began his career in education as a Math Teacher and 8th Grade Homeroom Teacher at Redeemer School, demonstrating from the outset a deep commitment to the students and community of Redwood City; and WHEREAS, prior to his principalship, Principal Mancini served as Head Football Coach and PE Teacher at Sequoia High School, and as Head Varsity Football and Baseball Coach and Math and PE Teacher at Carlmont High School, bringing the lessons of teamwork, discipline, and perseverance to students across the Peninsula; and WHEREAS, Principal Mancini is a graduate of Fresno State University and holds the School Leadership Educational Development (SLED) Certificate, equipping him with the academic foundation and leadership skills to guide Redeemer School with vision and integrity — and whose extraordinary athletic career as a punter for the San Francisco 49ers, Detroit Lions, and Green Bay Packers (1986–1988) instilled in him the values of excellence and resilience that he carried into every classroom and hallway of Redeemer School; and
WHEREAS, during his tenure as Principal, Michael Mancini oversaw the construction of a new school building and guided the growth of Redeemer’s student body from 90 to more than 200 students, reflecting the community’s unwavering trust in his leadership; and
WHEREAS, Principal Mancini curated a celebrated Middle School Public Speaking Program and established the signature 8th Grade Washington, D.C. trip, enriching the educational experience of generations of Redeemer students and preparing them for engaged citizenship; and
WHEREAS, Principal Mancini’s leadership was honored with the National Exemplary School Recognition in 2014, and he was recognized as Bay Area Middle School Coach of the Year in 2004; and his storied athletic career is further commemorated by his induction into the St. Francis High School Sports Hall of Fame and his historic distinction as the first punter to be named MVP in a college football bowl game at the 1985 California Bowl; and WHEREAS, over the course of 30 years of devoted service — from 1997 through 2026 — Principal Mancini has shaped the lives of countless students, earned the admiration of families and faculty alike, and strengthened the bonds of the Redeemer School community through his tireless dedication, warmth, and unwavering commitment to excellence in education.

NOW THEREFORE, BE IT RESOLVED THAT the City of East Palo Alto hereby recognizes and honors Principal Michael Mancini upon the occasion of his retirement and expresses its profound gratitude for his extraordinary 30 years of service to Redeemer Elementary School and to the children and families of our community. The City of East Palo Alto wishes Principal Mancini every happiness and fulfillment in the years ahead, and his legacy of excellence, compassion, and dedication shall endure in the hearts and minds of all those whose lives he has touched.

Dated: June 2, 2026

Webster Lincoln, Mayor
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EPASD CONSENT ITEM 8.1

EAST PALO ALTO

SANITARY DISTRICT

STAFF REPORT
DATE: June 2, 2026
TO: Honorable East Palo Sanitary District Board Members VIA: Melvin E. Gaines, General Manager
BY: Tomohito Oku, District Treasurer
SUBJECT: EPASD FY 2026-27 Proposed Budget
Recommendation
Staff recommends that the EPASD Board receive this report and provide feedback on the Fiscal Year 2026-27 proposed budget.

Background
The East Palo Alto Sanitary District (“EPASD” or “District”) was incorporated into the City of East Palo Alto as a subsidiary district effective October 1, 2024. The District is reported as a blended component unit of the City for financial reporting purposes while continuing to maintain its own enterprise fund, budget, and governing structure.

The FY2025–26 budget represented the first full budget cycle following the District’s incorporation into the City. The EPASD Board adopted the FY2025–26 budget on June 16, 2025, establishing the initial financial framework under City administration and reflecting the transition from the prior governance structure. The adopted budget was subsequently amended through the Mid-Year Budget Report in February 2026, primarily to carry forward encumbrances and unspent appropriations from the prior fiscal year to support ongoing projects and commitments.

Consistent with the City’s financial reporting framework, EPASD’s budget is incorporated into the City’s annual budget document as a separate enterprise fund. The District also continues to maintain standalone budget and audited financial statements to support transparency and preserve its operational identity.
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EPASD CONSENT ITEM 8.1
The proposed FY2026–27 budget builds upon the framework established in FY2025–26 and reflects ongoing efforts to align District operations with City financial practices, while ensuring the long-term sustainability of wastewater services.

This item was presented to the EPASD Advisory Committee on May 7, 2026 in advance of formal Board consideration to provide an opportunity for the Committee to review the proposed FY2026–27 budget, ask questions, and provide feedback. Input received from the Committee will be communicated to the EPASD Board during the presentation.

Analysis
FY 2025–26 Budget-to-Actual Update Through March 31, 2026 The table below shows the budget to Actual information for the fiscal year 2025-26 through March 31, 2026.

As of March 31, 2026, total operating expenditures are generally tracking below budget and are consistent with the timing of expenditures and ongoing operations. Total operating expenditures through the third quarter were approximately $4.25 million, or 63.6% of the amended operating budget. Several expenditure categories are expected to remain below budget at year-end, while certain contractual and treatment-related expenditures are anticipated to continue through the remainder of the fiscal year.

The West Bay Sanitary District operating contract budget was increased by approximately $200,000 as part of the FY2025–26 mid-year budget adjustments to reflect updated estimates for work orders and operational needs. Staff currently projects expenditures under the agreement to remain generally consistent with the amended budget through year-end.

Other operating expenditure categories, including building maintenance, utilities, and other Operating Expenditures Working Budget
FY25-26
YTD March
FY25–26 Variance % Change
Salaries and Benefits $ 459,471 $ 260,929 $ (198,542) -43.2% Treatment Contract 2,700,000 1,823,923 (876,077) -32.4% Operating Contracts 1,400,000 1,132,440 (267,560) -19.1% Engineering Services 601,175 52,679 (548,496) -91.2%
Legal Services 40,000 10,690 (29,311) -73.3%
Accounting and related Services 68,356 16,653 (51,703) -75.6% Insurance - - - #DIV/0!
Meeting, Travel, and Training 20,500 672 (19,828) -96.7% Other Operating Expenditures 268,416 107,241 (161,175) -60.0% Overhead Charges 1,123,373 842,530 (280,843) N/A
Total Operating
Expenditures $ 6,681,291 $ 4,247,756 $ (2,433,535) -36.4% Capital Expenditures $ 150,000 $ - $ 150,000
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EPASD CONSENT ITEM 8.1
miscellaneous operating costs, are also trending below budget and may result in year-end savings depending on expenditure activity during the final quarter of the fiscal year.

Certain operating contract expenditures may remain unspent at year-end due to the timing of ongoing projects and services. Consistent with prior practice, staff anticipates that outstanding contractual commitments and unfinished work associated with active projects will be encumbered and carried forward as part of the FY2026–27 mid-year budget adjustment process.

FY 2026-27 Proposed Budget Overview and Highlights
The District’s FY 2026-27 proposed budget is balanced, with total funding requirements fully supported by available funding sources. Total funding requirements, including capital projects, are $9.7 million, fully covered by $10.0 million in revenues, yielding a $0.3 million surplus. The table below provides a high-level overview of the District’s proposed budget compared to the prior year adopted budget.

FY 2026-27 Proposed Budget Analysis
The following table presents a detailed comparison of revenues and expenditures by category between the FY2025–26 adopted budget and the FY2026–27 proposed budget.

Operating revenues, which are primarily derived from sewer service charges, are projected to remain relatively flat at $5.3 million, reflecting no change in rate levels from the prior year. In contrast, operating expenditures are proposed at $7.1 million, representing an increase of $0.6 million (9.4%) compared to FY2025–26. This increase is primarily attributable to higher costs under the District’s operating and treatment agreements, including increased costs associated with services provided by West Bay Sanitary District.

Non-operating revenues—primarily consisting of property taxes, connection fees, and interest earnings—are budgeted at $4.7 million, reflecting a decrease of $3.7 million (43.9%) from the Description
FY 25-26
Adopted
FY 26-27
Proposed Variance
Total Revenues 13,701 10,041 (3,660)
Total Expenditures (6,603) (9,753) (3,150)
Net Sources / (Uses) 7,099 288 7,387
Net Transfers - - -
Change in Fund 7,099 288 7,387
FY 2026-27 - EPASD (In 000's)
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EPASD CONSENT ITEM 8.1
prior year. This decline is largely driven by a reduction in projected connection fee revenues (approximately $3.4 million), which are inherently variable and dependent on development activity. While property taxes and interest earnings are generally unrestricted and may be used to support both operations and capital, connection fee revenues are restricted for capital purposes and cannot be used to fund ongoing operating costs.

Capital expenditures are proposed to increase by $2.5 million, reflecting planned investment in two major sewer system replacement projects identified in the District’s Sewer Capital Master Plan. These investments are necessary to maintain system reliability and address aging infrastructure.

After accounting for all revenues and expenditures, the proposed budget results in a net increase in fund balance of approximately $0.3 million. The projected ending fund balance as of June 30, 2027 is estimated at $24.3 million. This reserve level remains strong relative to the District’s annual operating expenditures of $7.1 million and provides financial capacity to manage future capital needs and revenue volatility.

Adopted Budget Proposed Budget
FY2025-26 FY2026-27 %
Operating Revenue:

Sewer Service Charges $ 5,200,000 $ 5,200,000 $ - 0.0%
Other fees 50,000 100,006 50,006 100.0%
Total Operating Revenue 5,250,000 5,300,006 - 0.0%
Non-operating Revenues:

Property taxes 1,700,000 1,609,934 (90,066) -5.3%
Connection Fee 5,910,000 2,540,230 (3,369,770) -57.0%
Interest Income 805,000 554,681 (250,319) -31.1%
Rental Income 36,360 36,360 - 0.0%
Total Non-operating Revenues 8,451,360 4,741,205 (3,710,155) -43.9% Total Revenues $ 13,701,360 $ 10,041,211 $ (3,710,155) -27.1% Operating Expenditures:

Salaries and Benefits $ 459,471 $ 496,514 $ 37,043 8.1% Treatment Contract 2,700,000 2,875,884 175,884 6.5%
Contractual Services for Operation 1,200,000 1,880,000 680,000 56.7% Engineering Services 576,520 200,000 (376,520) -65.3%
Legal Services 40,000 41,600 1,600 4.0%
Accounting and related Services 57,100 71,200 14,100 24.7% Meeting, Travel, and Training 50,500 21,372 (29,128) -57.7% Other Operating Expenditures 245,716 242,666 (3,050) -1.2% Overhead Charges 1,123,373 1,228,837 105,464 9.4%
Total Operating Expenditures 6,452,680 7,058,073 605,393 9.4% Capital Expenditures 150,000 2,695,000 2,545,000 1696.7% Total Expenditures $ 6,602,680 $ 9,753,073 $ 3,150,393 47.7% Change in Fund Balance $ 7,098,680 $ 288,138 $ (6,810,542) -95.9% Projected ending reserve $ 24,295,138
Variance
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EPASD CONSENT ITEM 8.1
Financial Outlook and Policy Considerations
Based on the proposed budget, the District is projected to experience an operating deficit of approximately $1.8 million (operating revenues less operating expenditures). This deficit is effectively subsidized by non-operating revenues, such as property taxes and interest earnings, as connection fee revenues are restricted for capital use and cannot be used to support operations. The presence of this structural operating deficit raises a key policy question regarding whether sewer service rates should be adjusted to more fully recover the cost of operations, rather than relying on non-operating revenues.

This consideration becomes more critical in light of anticipated future cost pressures. The District expects significant increases in treatment costs under its agreement with the City of Palo Alto in the coming years. In addition, the District faces ongoing capital infrastructure needs identified in its Sewer Capital Master Plan. Together, these factors highlight the need for a comprehensive, long-term financial plan that addresses both operating and capital funding requirements, which may include a combination of rate adjustments, strategic use of reserves, and potential debt issuance.

Staff will return to the Advisory Committee and Board with a long-term financial strategy in a future agenda to further evaluate these issues and provide recommendations for policy direction.

Environmental
The proposed action is not a “project” under California Environmental Quality Act (CEQA) pursuant to CEQA Guideline section 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 involves no entitlement.

Analysis of Levine Act Compliance: Not applicable.
121
FY27
Expense Detail request (Excl. Payroll)
Department / Fund: East Palo Alto Sanitary District (Fund 530) Fund Division Proposed FY27
53101 Staff Augmentation
530 21212 Staff Augmentation - Temp Employee through AppleOne 80,000 Subtotal 80,000
53201 Other Professional and Technic
530 21212 Palo Alto Treatment 2,875,884
530 21212 West Bay Contract 1,800,000
530 ⟳ 21212 Freyer & Lauretta Engineering Services- both cost recovery and staff aug 100,000 530 ⟳ 21212 EKI Technical Services - On Call 100,000
Subtotal 4,875,884
53210 Legal and Accounting Services
530 12121 Legal and Accounting Services - Legal Advise-Colantuono 41,600 530 ▲★ 13131 EDS Tax Roll Consultant 30,000
530 13131 EPASD Data Service Tax Roll 2,300
530 13131 Audit 20,600
530 13131 Bartel (GASB68) Report 3,300
530 13131 County PPT Fees 10,000
530 13131 OPEB Actuarial Study (2 Reports) 5,000
Subtotal 112,800
54240 Building Maintenance
530 21213 Building Maintenance
530 21213 Building Maintenance - Alarm and others 32,000 530 21213 Degree HVAC 1,000
530 21213 Rodent Control 2,500
530 21213 Elevator 1,000
530 21213 Everon 12,876
530 21213 A-1 Septic Tank Service @ Cooley Landing 5,000 530 21213 Simonds Machinery-Cooley Landing Sewer Pumps 10,000 530 21213 Misc. 50,000
Subtotal 114,376
54280 Janitorial Services
530 21213 Janitorial Services 30,000
Subtotal 30,000
55300 Communications
530 21212 EPASD Landlines and internet 9,000
530 95952 Communications 15,040
Subtotal 24,040
55400 Advertising
530 21212 Advertising - Publication & Legal Notice 5,000 Subtotal 5,000
55410 Printing and Binding
530 21212 Printing and Binding 500
Subtotal 500
55600 Meeting and Catering
530 21212 6 Advisory Commission Meetings, any meetings at EPASD 1,500 Subtotal 1,500
Detail
122
FY27
Expense Detail request (Excl. Payroll)
Department / Fund: East Palo Alto Sanitary District (Fund 530) Fund Division Detail Proposed FY27
55800 Transportation and Training
530 10101 Training for board members (PY was $18K) 7,500 530 12121 Special District Conference 2,000
530 21212 MMANC Women’s Leadership Summit Conference - Sacramento, CA 550 530 21212 Municipal Management Association Northern CA Conference - Yosemite 2,800 530 21212 CWEA Annual Conference & Expo (AC26) 3,400
530 21212 Transportation and Training
Subtotal 16,250
55910 Membership and Dues
530 21212 CWEA Membership (PW Director, Utility Manager, Admin Asst) 753 530 21212 APWA Membership (PW Director, Utility Manager, Admin Asst) 869 530 21212 California Special Districts Association (CSDA) 2,000 530 21212 Membership and Dues
Subtotal 3,622
55920 Special Events
530 21212 Special Events 500
Subtotal 500
60207 Utilities
530 21212 Utilities - PG&E, Water, Recology 50,000
Subtotal 50,000
60208 Fuel
530 21212 Fuel 250
Subtotal 250
60209 Other Operating Supplies
530 21212 Other Operating Supplies 5,000
Subtotal 5,000
60301 General Office Supplies
530 21212 General Office Supplies 1,000
Subtotal 1,000
70410 Furniture & Equipment Under $5K
530 ▲ 21212 Furniture & Equip Under$5k 12,000
Subtotal 12,000
90310 Overhead Allocation
530 95951 Cost allocation 1,055,900
530 95952 IT Overhead Allocation 172,937
Subtotal 1,228,837
▲ One-time expense
⟳ Periodic expense (ex: every 5 years)
★ Strategic Priorities Workplan Fund 530 Total 6,561,559 123
INFORMATIONAL REPORT 11.1

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: June 2, 2026
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Humza Javed, Public Works Director
Batool Zaro, Senior Engineer
SUBJECT: Parking Conditions along Woodland Avenue
Recommendation
Receive the informational report and presentation.

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

Public Health, Safety, and Quality of Life
Background
Woodland Avenue is a connector roadway that runs in the north-south direction, serving traffic in both directions. Between University Avenue and West Bayshore Road, this section of Woodland Avenue lacks sidewalk and bike lanes. Moreover, due to the narrow roadway width, there isn’t enough space for parking along both sides of the corridor.

Over the years, the City of East Palo Alto (City) staff have received many complaints regarding improper parking along the corridor. In addition to parking issues, there is also a concern with illegal dumping and encampments along Woodland Avenue.

Due to Woodland Avenue’s proximity to the San Francisquito Creek (the Creek), which is located just to the west of Woodland Avenue, illegal dumping and encampments pose a significant risk to water quality and the surrounding environment.

On April 16, 2025, the Public Works and Transportation Commission (PWTC) received a presentation from staff regarding parking concerns along Woodland Avenue from University 124
INFORMATIONAL REPORT 11.1
Avenue to West Bayshore Road. The PWTC was supportive of parking restrictions along the corridor but noted the need to engage the residents who utilize on-street parking, police enforcement, and emphasized the importance of safety and cleanliness.

Analysis
At the January 20th, 2026, City Council Meeting, the City Council discussed parking restrictions along the west side of Woodland Avenue from University Avenue and West Bayshore Road. At the meeting, City Council requested additional information on the existing conditions for a better understanding of the parking limitations. Additionally, the Council requested further discussion on parking alternatives.

Staff will be presenting an information presentation to the City Council informing them of the existing conditions, potential improvements and future next steps.

Fiscal Impact
None.

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 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.

Government Code § 84308
Applicability of Levine Act: No.

Analysis of Levine Act Compliance: Not applicable.

Attachments
None
125
PUBLIC HEARING 13.1

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: June 2, 2026
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Alvin Jen, Associate Planner
Elena Lee, Planning Manager
Natasha Raiburn, Interim Community and Economic Development Director Shiri Klima, Assistant City Manager
SUBJECT: City of East Palo Alto Vista 2035 General Plan Safety and Noise Element and Infrastructure, Services, and Facilities Element Update Recommendation
Adopt a resolution to:

1. Approve the proposed amendments to the East Palo Alto Vista 2035 General Plan to update the Safety and Noise Element and the Infrastructure, Services, and Facilities Element; and

2. Find that the amended elements comply with recent changes to California State law governing General Plan Safety Elements; and

3. Incorporate by reference the San Mateo County Multijurisdictional Local Hazard Mitigation Plan including the City of East Palo Alto Annex into the Safety and Noise Element; and

4. Find that the project is exempt pursuant to a common-sense exemption under the California Environmental Quality Act (CEQA) Guidelines Section 15061(b)(3) because it can be seen with certainty it would not result in a significant environmental impact.

Executive Summary
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PUBLIC HEARING 13.1
The City of East Palo Alto is proposing to update two elements of its Vista 2035 General Plan, the Safety and Noise Element and the Infrastructure, Services, and Facilities Element. The update is intended to bring both elements into full compliance with State law, incorporate findings from the 2025 Climate Change Vulnerability Assessment (Exhibit F), reflect updated hazard information, and advance community resilience priorities identified through a multi-year public engagement process. The updates were prepared as part of the Peninsula Resilience Planning (PREP) multi-jurisdictional collaborative in San Mateo County. The planning process included virtual and various in-person community workshops conducted in several languages, targeted outreach to underrepresented communities, coordination with outside services providers, publication of draft documents for a 30-day public review and comment period, and review by State agencies.

The proposed updates expand the goals and policies of the Safety and Noise Element by adding new sections addressing sea level rise, extreme heat, air quality, emergent groundwater, and hazardous materials, while also strengthening emergency preparedness measures. The Infrastructure, Services, and Facilities Element retains its existing goals while updating policies that promote green infrastructure, improve stormwater and drought resilience, and address vulnerabilities to critical infrastructure. Upon adoption, both updated elements will replace the 2016 versions.

Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:
 Priority: Public Health, Safety, and Quality of Life
Background
The Safety and Noise Elements are State-mandated components of every city's and county's General Plan, as required under California Government Code Sections 65302(f) and 65302(g).

While they are addressed as separate statutory requirements, many jurisdictions, including East Palo Alto combine them into a single element. The Infrastructure, Services, and Facilities Element is not mandated by State law, however it has been included in the City's Vista 2035 General Plan to provide a vital policy basis for guiding shorter-term planning documents such as the Capital Improvements Program and the annual capital budget. The element is grounded in realistic analyses of existing infrastructure capacity and anticipated future demand. Together, these elements identify potential natural and human-caused hazards that could affect residents, businesses, infrastructure and public services within the community. The purpose of the Safety Element is to establish a comprehensive framework that identifies and anticipates these hazards and prepares the community to minimize associated risks and impacts.

The Safety and Noise Element identifies the natural and human-caused hazards that affect East Palo Alto, describes present and expected future conditions, and sets goals and policies aimed at minimizing hazards and threats to public safety. This includes efforts to protect the health and safety of community members, minimize damage to the buildings and infrastructure, and reduce disruption to local economic systems, community services, and ecosystems. 127
PUBLIC HEARING 13.1
State Law Requirements for Safety Elements
California Government Code Section 65302(g) establishes requirements for Safety Elements, including that they must be updated upon each revision of the Housing Element or Local Hazard Mitigation Plan, but not less than once every eight years. Key legislative changes that have significantly expanded these requirements include:
 SB 379 (2017), codified in Section 65302(g)(4), requires local governments to conduct climate change vulnerability assessments as part of their long-range planning efforts and to prepare resilience and adaptation policies.
 SB 1035 (2018) established Section 65302(g)(6), requiring jurisdictions to review and update the Safety Element upon updates to the Housing Element and Hazard Mitigation Plan, or at least every eight years. Any revisions should include updated information related to flood hazards, fire hazards, and climate adaptation and resilience, along with other relevant topics.
 SB 99 (2019) established Section 65302(g)(5) and requires jurisdictions to review and update the Safety Element to include information identifying residential developments in hazard areas that do not have at least two emergency evacuation routes.  AB 747 (2019) established Section 65302.15. It requires jurisdictions to identify evacuation routes and their capacity, safety, and viability. AB 1409 (2021) amended this section to include identifying evacuation locations. This requirement is being addressed by the county-wide All-Hazards Evacuation Plan, which is currently in progress and in which East Palo Alto is participating.
 AB 2684 (2024) added Section 65302.01, requiring jurisdictions to identify areas most vulnerable to extreme heat, assess health and infrastructure risks, and include goals, policies, and implementation measures to address those risks.

The above statutory requirements are already in effect, with the exception of AB 2684, which takes effect January 1, 2028. This element is designed to address all applicable requirements, including proactive steps toward compliance with AB 2684 in advance of its effective date.

Purpose of the Safety and Noise Element Update
The current Safety and Noise Element was adopted in 2016 as part of the City’s comprehensive update of its Vista 2035 General Plan. This current update brings the Safety Element into full compliance with the State law, incorporates the results of a new climate vulnerability assessment, and reflects updated hazard information and community priorities. Following the 2024 Housing Element update, SB 1035 requires review and revision of the Safety and Noise Element. The updated element includes new and revised goals, policies, and implementation actions addressing identified hazards.

Purpose of the Infrastructure, Services, and Facilities Element Update The Infrastructure, Services, and Facilities (ISF) Element, adopted as part of the Vista 2035 General Plan in 2016, also has not been updated. Since then, changes to infrastructure 128
PUBLIC HEARING 13.1
conditions, regulatory requirements, and climate risks have necessitated updates. Key drivers include:
 State Law Requirements and General Plan Consistency:
o SB 1383 (2016) established mandatory organic waste diversion requirements that necessitate updated solid waste and recycling policies beyond those previously adopted.
o AB 32 (2016) (as updated by SB 32 (2016) and AB 1279 (2022)) set revised greenhouse gas reduction targets for 2030 and 2045 that require integration into infrastructure-related climate policies.
o State housing law, including RHNA cycle obligations, requires the City to demonstrate that water supply, sewer capacity, and public facilities can adequately serve projected growth.
 Climate Change Vulnerability Assessment (2025). The most consequential driver of the ISF Element’s update is the City’s completion of a Climate Change Vulnerability Assessment in 2025. This assessment (Exhibit F) is an appendix to the Safety and Noise Element, identified flooding, extreme heat, sea level rise, and severe weather as priority hazards specifically threatening the City’s infrastructure and service delivery systems.  Updated Infrastructure Data and Changed Conditions. Changes to the City’s infrastructure conditions since 2016 require updating the background analysis section of the element.
 General Plan Update Coordination. Changes to the Safety and Noise Element, and Housing Element have cross-referenced various elements that require the ISF Element to be updated for consistency.
 Operational and Programmatic Improvements. The City and its partner agencies have made progress on several priorities identified in the 2016 element. The 2026 update reflects completed or advanced work in areas including: an updated Climate Action Plan implementation, participation in OneShoreline (San Mateo County Flood and Sea Level Rise Resiliency District) and the OneWatershed framework for regional climate resilience, and expanded organics recycling and implementation of residential food waste collection under SB 1383.
 Interdepartmental and Service Provider Collaboration. City staff were engaged throughout the update process, providing substantive input to reflect changes since the 2016 Safety and Noise Element, and reviewing and revising a preliminary draft prior to the release of this public draft. Outside agencies and service providers, including the Menlo Park Fire Protection District, Veolia Water, and West Bay Sanitary District, also contributed to the update, informing content relevant to their areas of service.

The PREP Project
The Safety and Noise Element update was prepared as part of the Peninsula Resilience Planning (PREP) project, a multi-jurisdictional collaborative in San Mateo County that began in 2023. Participating jurisdictions include San Mateo County, Atherton, Belmont, Brisbane, Burlingame, East Palo Alto, Half Moon Bay, Pacifica, and San Bruno. While San Mateo County’s Planning and Building Department is the funding agency, each jurisdiction has been working with a consulting team led by PlaceWorks, along with the Community Planning Collaborative 129
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(CPC) and a local non-profit, Climate Resilient Communities (CRC). The collaborative approach allowed participating jurisdictions to share technical analyses and resources for greater efficiency and consistency across the region.

The PREP project began in 2023 with vulnerability assessments and community engagement conducted in 2024 and 2025. Concurrently, interdepartmental and outside service provider coordination meetings were held, informing updates to key documents including the Background Report and Vulnerability Assessment. The draft Safety and Noise Element and Infrastructure, Services, and Facilities Element were released for public review on March 25, 2026, for a 30- day public comment period, with anticipated adoption hearings to City Council in June 2026.

Public Outreach
Community engagement is central to the Safety and Noise Element update process, guided by the five core principles of inclusion, equity, transparency, participation, and accountability. The project team prioritized reaching hard-to-reach and historically underrepresented communities, ensuring their voices helped to shape the policies in the updated Safety Element.

Engagement occurred in three primary phases, with public outreach as an essential component throughout the entire process
 Phase 1 (March 2024–June 2024) focused on the vulnerability assessment, gathering community input on hazard experiences, identifying vulnerable populations and assets, and understanding challenges related to disaster preparation and recovery.  Phase 2 (November 2024–May 2025) focused on presenting vulnerability assessment results and draft policy concepts to gather community feedback on proposed resilience strategies.
 Phase 3 (March 2026 – June 2026) focuses on public review and comment of draft documents and adoption process, providing additional opportunity for formal public review and input.

Specific engagement activities conducted included:
 Project Website (prepsmc.com): A comprehensive project website served as the central hub for project information, document libraries, event announcements, and community engagement tools. Workshop recordings were posted in English and Spanish for residents unable to attend live sessions. The City also had a dedicated website (https://www.cityofepa.org/planning/page/safety-element-update) with updated information, which included project timeline, updated materials, upcoming outreach events and staff contact.
 Digital Engagement Tools: An interactive, map-based online survey allowed community members to provide location-specific input on hazard experiences and vulnerabilities in their neighborhoods. An online map viewer provided public access to the same hazard mapping layers and vulnerability assessment datasets used in the technical work. An interactive story map, combining mapping with background text and graphics, provides additional detail about hazards and climate vulnerabilities with location-specific 130
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information and profiles for each community.
 Virtual Community Workshops: Project staff held three county-wide virtual workshops, two in spring 2024 (138 registrants; 70 attendees) and one in May 2025 (80 registrants; 28 attendees). Workshops included presentations, polling, and facilitated small-group breakout discussions. All workshops offered simultaneous Spanish interpretation and Spanish-language materials.
 In-Person Community Workshops: The City was awarded a Climate Smart Communities Initiative (CSCI) grant that provided additional opportunities to host in person workshops, focus groups and pop-up events. The City, In partnership with CRC, facilitated these events that were held at the East Palo Alto YMCA and the Farmers Market at Bloomhouse. Outreach events held during summer 2025 provided residents and stakeholders with opportunities to help inform draft policies prior to release of the public draft.
 Service Provider Discussions: Project staff held virtual discussions with representatives of 24 community organizations grouped into eight categories (chambers of commerce, community service organizations, energy providers, environmental groups, faith-based organizations, public health organizations, transit providers, and water/wastewater providers). Key themes included infrastructure vulnerability, extreme heat preparedness, funding barriers, and the value of interjurisdictional cooperation.  Communities of Concern Meetings: CRC, City staff, and members of the project team led a series of in-person, small-group meetings focused on reaching residents in historically underrepresented communities. Targeted areas included North Fair Oaks, Pescadero, coastal areas near Half Moon Bay, and East Palo Alto. Meetings were conducted in culturally appropriate formats, with food, translation services, and participant compensation.

Analysis
Summary of Changes to the Safety and Noise Element1
The updated element reflects expanded State requirements and local priorities identified through the public planning process. Key changes include:
 Expanded coverage of climate change vulnerability, including the results of the PREP vulnerability assessment, which analyzed current and projected future risks to people, buildings, infrastructure, and key services from a range of climate hazards. All information about existing hazard conditions was reviewed and updated as needed.  Expanded content on emergency evacuation, including an analysis of residential areas that may lack two or more emergency evacuation routes, consistent with SB 99 requirements.
 New policies addressing extreme heat, severe weather, and drought  Updated flood and sea level rise policies reflecting current hazard information, including updated FEMA flood maps and projections for sea level rise, emergent groundwater, and

1 Tracked changes version of the draft element, with all changes redlined, is provided as Attachment 2. A clean version of the draft element is provided as Exhibit C.
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tsunamis.
 Updated hazard maps for all major hazard categories.
 A background report (attached as Appendix A to the Safety and Noise Element, Exhibit E of the packet), documenting the current state of all hazards discussed in the element.

The 2026 draft expands from 8 goals and approximately 50 policies (2016) to 15 goals and approximately 124 policies. New goal areas include:
 sea level rise/coastal flooding (SN-4),
 emergent groundwater (SN-5),
 air quality (SN-7),
 community resilience to severe weather events (SN-8),  extreme heat (SN-9)
 water security (SN-10),
 protection from hazardous materials (SN-12, previously included as a combined goal, now separate).

Additionally, the emergency preparedness goal (formerly SN-5, now elevated to SN-1) has been significantly expanded from 8 to 21 policies and is being coordinated with the City’s emergency preparedness team, who are actively tracking progress on related projects.

The organization of the element has also changed, with emergency preparedness and response elevated to the first goal, reflecting City Council priorities around public safety and disaster readiness. The element now opens with a Climate Change Vulnerability section that establishes an analytical framework grounded in the 2025 Vulnerability Assessment (Exhibit F), Cal-Adapt projections, and the California Adaptation Planning Guide2. Environmental justice considerations are woven throughout the document rather than addressed in isolation.

The table below summarizes the changes introduced in this update compared to the 2016 Safety and Noise Element.

Expanded/Modified New Goal Largely Retained
2016 Goal 2016 Policy
Count 2026 Draft Goal 2026 Policy Count Status
SN-1: Reduce risk from
earthquakes and geologic
hazards
4 policies SN-2: Reduce risk to people
and property from
earthquakes and other
geologic hazards
4 policies Expanded

2 Cal-Adapt is California's official climate data platform, developed by the California Energy Commission, providing downscaled climate model projections localized to California communities. The City's 2025 Vulnerability Assessment draws on Cal-Adapt outputs to project hazard conditions for East Palo Alto from 2035–2099. The California Adaptation Planning Guide (APG), published by the Governor's Office of Planning and Research, establishes the state-recommended methodology for local vulnerability assessments as required under Senate Bill 379 (2015), structuring analysis around four components: exposure, sensitivity, potential impacts, and adaptive capacity.
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2016 Goal 2016 Policy
Count 2026 Draft Goal 2026 Policy Count Status
SN-2: Provide adequate flood
control and storm drainage
to minimize flooding risk
7 policies SN-3: Provide adequate flood
control and storm drainage
to minimize flooding risk
14 policies Expanded
SN-3: Reduce risk of fire and
wildfire hazards in the
community
6 policies SN-6: Reduce risk of fire and
wildfire hazards in the
community
8 policies Expanded
SN-4: Protect community
from hazards related to
aircraft, surface
transportation, and
hazardous materials
6 policies SN-11: Protect community
from public safety hazards
related to aircraft, surface
transportation, and
hazardous materials
3 policies Expanded
SN-5: Provide efficient and
effective emergency
response in the aftermath of
a natural or human-caused
disaster
8 policies SN-1: Provide efficient and
effective emergency
response in the aftermath of
a natural or human-caused
disaster
21 policies Reordered &
Expanded
SN-6: Minimize effects of
noise through proper land
use planning
5 policies SN-13: Minimize effects of
noise through proper land
use planning
6 policies Expanded
SN-7: Minimize
transportation- and nontransportation-related noise
impacts, especially on noisesensitive land uses
11 policies SN-14: Minimize
transportation- and nontransportation-related noise
impacts especially on noisesensitive land uses
11 policies Largely
Retained
SN-8: Coordinate land use
planning to prevent new odor
complaints
3 policies SN-15: Coordinate land use
planning to prevent new odor
complaints
3 policies Retained
— — SN-4: Protect community
from sea level rise through
adaptive planning, regional
coordination, and resilient
infrastructure development
10 policies NEW
— — SN-5: Safeguard residents
and infrastructure from
emergent groundwater
hazards while preventing
contamination mobilization in
vulnerable communities
5 policies NEW
— — SN-7: Ensure clean air and
protect public health through
regional collaboration,
equitable planning, and
sustainable development
11 policies NEW
— — SN-8: Enhance community
resilience to severe weather
events through severe
weather events through
improved infrastructure,
emergency preparedness,
5 policies NEW
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2016 Goal 2016 Policy
Count 2026 Draft Goal 2026 Policy Count Status
and coordinated response
capabilities
— — SN-9: Enhance community
resilience to extreme heat
11 policies NEW
— — SN-10: Ensure water security
and community resilience
during drought conditions
through conservation,
efficiency measures, and
sustainable water
management practices
5 policies NEW
— — SN-12: Protect community
health and rom hazardous
materials
exposure through
responsible
management, remediation of
contaminated sites, and
prevention of
new contamination
7 policies NEW
The most significant structural change in the 2026 draft is the reorganization of the Safety and Noise Element into a comprehensive climate resilience document. Where the 2016 element treated sea level rise as a secondary consideration within the flooding section, the 2026 draft establishes a dedicated Climate Change Vulnerability section upfront and adds new hazardspecific goals. This reflects the requirements of SB 379 (2015) and positions the General Plan in compliance with the California Adaptation Planning Guide methodology.

The addition of Goal SN-5 addressing emergent groundwater, a hazard that did not appear in the 2016 element. As sea levels rise, shallow groundwater beneath East Palo Alto is projected to surface in portions of the City by 2050 and more extensively by 2100 (Figures 10-9 and 10- 10). This creates new risks of damage to public and private property and infrastructure.

Goal SN-12 Protection from hazardous materials and Goal SN-7 Air Quality are newly added to address identified community vulnerabilities. In East Palo Alto, existing tree canopy conditions combined with a higher proportion of lower-income households residing in older housing often lacking adequate air conditioning and air filtration systems contribute to elevated exposure risks and make air quality a significant public health concern.

The elevation of emergency preparedness to Goal SN-1 (from SN-5 in 2016) and its expansion from 8 to 21 policies is among the most significant organizational and substantive changes. New policies address gaps identified in the 2016 element, including the absence of a standardized evacuation plan (currently being remedied through the county All-Hazards Evacuation Plan), the mapping of single ingress/egress residential parcels per SB 99 and AB 747, and equitable emergency services delivery. New Policy SN-1.21 Equitable Emergency Response, which requires monitoring and reporting of response time data to ensure East Palo Alto receives 134
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comparable emergency services to surrounding communities. This reflects community concerns about service equity and provides a measurable implementation standard. New Policy SN-1.12 Community Resilience Centers and Policy SN-1.13 Flexible-use public facilities establish a framework for infrastructure that can serve everyday civic functions while also being rapidly converted into emergency shelters or response sites during disaster or other emergency events.

The seismic and geologic hazards goal has been updated with more fault probability data from the United States Geological Survey (USGS). The liquefaction hazard zone has been expanded, and all of East Palo Alto is now mapped as liquefaction-susceptible, compared to the 2016 focus on baylands and the US-101 corridor. These updated maps reflect more accurate scientific data about existing conditions rather than imposing new hazards or mandatory retrofit requirements on existing homeowners not planning to make improvements. New construction and substantial improvement projects within liquefaction hazard zones will be required to undergo site-specific geotechnical investigations to ensure safe building practices. The City recognizes that expanded hazard designations may affect insurance availability and affordability for residents. The City has and will continue to facilitate access to technical and financial assistance programs that prioritize low-income households and communities of concern where applicable programs exist.

New Policy SN-2.4 requires site-specific geotechnical investigations for new development in liquefaction and tsunami zones, consistent with the Building Code and implementing what was previously discretionary review guidance. The 2026 draft also addresses the compounding effects of climate change on seismic hazards. For example, rising groundwater levels increasing liquefaction susceptibility during seismic events.

The noise and odor provisions (now Goals SN-13 through SN-15) have been retained substantially intact from 2016. Interior and exterior noise standards (Table 10-1) remain unchanged. The Union Pacific/Dumbarton Rail Corridor noise provisions are carried forward.

Minor updates reflect revised airport land use coordination language. Staff did not identify significant issues with the noise element update.

The 2016 Safety and Noise Element did not explicitly address environmental justice. This draft integrates environmental justice considerations throughout, in compliance with SB 1000 (2016).

It includes policies that promote equitable service delivery, multilingual and multi-format emergency communications, and targeted assistance for low-income households and renters located in flood and fire hazard areas. The Safety Element also aligns with the forthcoming Environmental Justice Element to ensure internal consistency and policy coordination within the General Plan.

Summary of Changes to the Infrastructure, Services, and Facilities Element3 The 2026 draft ISF Element constitutes as a revision rather than a comprehensive update, retaining the ten goal structure established in 2016 while refining policies to reflect current

3 The tracked changes version of the draft element, showing all changes as redlined, is provided as Attachment 3.

The clean version of the draft element is included as Exhibit D. 135
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conditions and State law requirements. Key changes include:
 Transition from permissive to mandatory for green infrastructure requirements;  New climate resilience provisions to stormwater, sewer, and telecommunications goals;  Updated solid waste policies to comply with SB 1383 organic waste mandates;  New infrastructure vulnerability assessment policy requirements including updating the water supply section to reflect the 2023 Climate Action Plan and drought resilience needs.

The table below provides a goal-by-goal comparison with a summary of key policy changes within each goal area.

Expanded/Modified New Goal Largely Retained
2016 Goal 2016 Policy Count 2026 Draft Goal 2026 Policy Count Status ISF-1: Manage stormwater
safely,
efficiently, and sustainably
12 policies ISF-1 Manage stormwater
safely, efficiently, and
sustainably
14 policies Expanded
ISF-2: Ensure a
sustainable,
clean, long-term water
supply
13 policies ISF-2: Ensure a sustainable,
clean, long-term water
supply
15 policies Expanded
ISF-3: Provide a wellmaintained
sewer system for the
community
2 policies ISF-3: Provide a wellmaintained sewer system 2 policies Updated
ISF-4: Use best practices to
reduce and manage solid
waste
9 policies ISF-4: Use best practices to
reduce and manage solid
waste
10 policies Expanded
ISF-5: Fund construction
and
maintenance of basic
infrastructure
and public facilities
4 policies ISF-5: Fund construction
and maintenance of basic
infrastructure
5 policies Expanded
ISF-6: Ensure safe and
well-maintained
telecommunications
services
4 policies ISF-6: Ensure safe and wellmaintained
telecommunications
4 policies Updated
ISF-7: Ensure high-quality
educational opportunities
for East
Palo Alto students
10 policies ISF-7: Ensure high-quality
educational opportunities
for East Palo
Alto students
11 policies Expanded
ISF-8: Provide high-quality
public and civic facilities
for the
community
8 policies ISF 8 : Provide high-quality
public and civic facilities for
the community
8 policies Retained
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The most substantive policy change in the ISF Element is the transition from permissive to mandatory green infrastructure requirements. The 2016 element encouraged green streets and bio-retention, whereas the 2026 draft requires installation of green infrastructure elements including bioretention areas, pervious surfaces, and diverse native trees when public rights-ofway undergo major modifications. Similarly, stormwater best management practices are now required, not merely encouraged.

The new Policy ISF-1.10 Stormwater System Resilience to Sea Level Rise is an important forward-looking provision requiring evaluation of the stormwater system including pipe capacity, pump performance, and outfall function under projected sea level rise and emergent groundwater conditions. This complements the O'Connor Pump Station improvements and approximately $37.5 million in other capital improvements identified in the 2015 Storm Drain Master Plan.

Three new policies strengthen the drought resilience strategies, Policy 2.10 directs the City to work with San Francisco Public Utilities Commission (SFPUC) to prepare for reduced long-term water supply from more frequent and severe droughts, Policy 2.14 introduces rainwater catchment systems in public rights-of-way, and Policy 2.15 establishes a community partnership framework for water conservation retrofits targeting low-income homeowners. The latter two policies align with the 2023 Climate Action Plan goals and represent concrete implementation mechanisms.

New Policy ISF-5.5 Priority Community Infrastructure Assessment fills a gap in the 2016 element, which contained no framework for systematically evaluating infrastructure vulnerability.

This new policy requires comprehensive vulnerability assessments of critical infrastructure to identify flood risks, structural deficiencies, and capacity limitations, explicitly incorporating sea level rise and emergent groundwater projections.

New Policy ISF-7.11 School Climate Resilience reflects the 2025 Vulnerability Assessment finding that several Ravenswood City School District (RCSD) schools are in areas vulnerable to flooding, extreme heat, and potential liquefaction. This policy requires coordination between the City and the school district to ensure school facilities are climate-resilient and can serve as community resilience centers during emergencies. The City has provided RCSD weblinks to the public draft on March 25, 2026. At the time of this staff report, staff have not received any comments from RCSD.

New Policy ISF-10.10 Emergency Infrastructure Resilience and new Policy ISF-4.10 Emergency Sanitation and Waste Management together address the continuity of basic ISF-9: Maintain and pursue
services, programming,
and humane
social policies to serve the
community and improve
quality of
life
8 policies ISF-9: Maintain and pursue
services, programming, and
humane social policies to
serve the community and
improve quality of life
8 policies Retained
ISF-10: Provide excellent
emergency services to the
community
9 policies ISF-10: Provide excellent
emergency services
10 policies Expanded
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services during extended emergencies. Both policies recognize that water, sanitation, and waste management are lifeline services whose failure during a disaster can significantly worsen public health outcomes, particularly for high-density and underserved communities.

Public Comment
The City received five (5) comment letters during the public comment period which concluded at the end of business day on April 24, 2026. Four comment letters were received during the public comment period, however they arrived after publication of the Planning Commission packet on April 23, 2026 (see Attachment 4). Staff has prepared a comment matrix summarizing each letter and staff’s responses, which was also shared during staff’s presentation at the April 27, 2026, Planning Commission hearing. (see Attachment 5).

Comment letters were received from Nuestra Casa (on the ISF Element); the Peninsula Accountability for Contamination Team (PACT — a coalition including Nuestra Casa, El Concilio of San Mateo County, Belle Haven Empowered, Climate Resilient Communities, Youth United for Community Action (YUCA), and SPUR); Save The Bay; and the Sierra Club Loma Prieta Chapter, Green Foothills, the Citizens Committee to Complete the Refuge, and resident (all on the Safety Element). For all comment letters, staff reviewed all the requests whether they were addressed already in the Safety or other General Plan Elements and also in the City’s Municipal Code or other regulations. Staff then evaluated how to best address issues that were not already addressed. Staff’s specific responses are summarized in the attached comment matrix (Attachment 4). The table below summarizes the comment letters received. # Organization(s)/Submitter Date Element
1 Frederico Andrade-Garcia March 25,
2026
Both
2 Nuestra Casa April 24,
2026
ISF Element
3 Peninsula Accountability for Contamination Team (PACT) Coalition: -Nuestra Casa -El Concilio of San Mateo County -Belle Haven Empowered -Climate Resilient Communities -Youth United for Community Action (YUCA) -SPUR
April 23,
2026
Safety Element
4 Save The Bay April 24,
2026
Safety Element
5 Sierra Club Loma Prieta Chapter · Green Foothills · Citizens Committee to Complete the Refuge
April 24,
2026
Safety Element
Nuestra Casa's comments focused on Goal ISF-2, requesting that community outreach and transparency on water systems extend beyond conservation to address community trust in water sources and water system monitoring; that the City proactively pursue named external funding sources for water infrastructure; and that the ISF Element adopt implementation timeframes and commit to annual public progress reporting.

In response, staff made targeted edits to both elements. In the ISF Element, Policy 2.11 was 138
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revised to require that public education include information about drinking water sources and relevant updates to the Water System Master Plan and Urban Water Management Plan, and that all outreach materials be provided in multiple languages directly responding to Nuestra Casa's comments on community trust and multilingual access.

Safety Element commenters collectively requested clearer policy language, consistent implementation timeframes, an external funding direction for the Storm Drain Master Plan, enforceable flood and sea level rise development standards, stronger groundwater investigation requirements, vapor intrusion screening near contaminated sites, and a new policy addressing biosafety standards for life sciences laboratory uses.

The Sierra Club Loma Prieta Chapter, Green Foothills, and San Francisco Bay Citizens Committee to Complete the Refuge submitted comments focused on the enforceability of flood, groundwater, and hazardous material policies and the consistency of development standards across the city. Most comments were found to be already addressed through existing regulations and were noted as such in the comment matrix.

Two examples from the comment matrix illustrate staff's approach. On the request for an enforceable, citywide flood-resilient development standards framework, staff found this addressed through the existing Development Code which already requires 50% permeable surfaces for single-family front yards and C.3/C.6 stormwater compliance and through Policy 4.1 and IM 4.1a, which already direct an update to the Floodplain Management Ordinance incorporating sea level rise projections. On the request for a new biosafety level policy for life sciences laboratory uses, staff found this would be addressed through the 2024 Ravenswood Business District Specific Plan, which already establishes a tiered Biosafety Lab (BSL) framework: BSL-1 and BSL-2 are permitted by right or administratively, BSL-3 requires a Conditional Use Permit with buffering findings, and BSL-4 is prohibited. Comments on strengthening geotechnical investigation requirements under Policies 5.2 and 5.4 and extending RBD standards citywide were noted but resulted in no changes, with staff pointing to ongoing OneShoreline coordination and future Council direction as the appropriate pathways.

In the Safety Element, staff added implementation timeframe labels throughout the goals and policies, strengthened language in existing policies, and expanded several narrative sections with updated data. With respect to comments on emergent groundwater and sea level rise, Policies SN-4 and SN-5 already commit the City to monitoring evolving conditions in coordination with local and state agencies and to using updated information to develop additional development requirements over time. Staff determined that these policies, together with the element's adaptive management framework, adequately address the substance of those comments without requiring new standalone policies.

On May 22, 2026, several organizations who provided public comment letters on the draft documents submitted a joint follow up letter to the Planning Commission and City Council (Exhibit H). In this letter, Nuestra Casa, YUCA, Belle Haven Empowered, Sierra Club Loma Prieta Chapter, Green Foothills, SPUR, San Francisco Bay Citizens Committee to Complete the Refuge, and Greenbelt Alliance raised concerns that comment letters submitted by the April 24, 139
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2026 deadline were not included in the Planning Commission agenda packet or addressed in the staff report, given the hearing was held three days later on April 27, 2026. The organizations requested that future public comment deadlines allow adequate time for review, that all submitted letters be published in the project record, and that Council staff reports include a summary of comments and staff responses.

Staff notes that although the comment letters were received within the established public comment period, they arrived after the publishing cutoff for the Planning Commission agenda packet. Staff transmitted the letters to Planning Commissioners on the day they were received and provided hard copies at the meeting to ensure Commissioners had access to the comments prior to their deliberations. All comments received including those in the joint letter have been reviewed, incorporated into the comment matrix (Attachment 5), and addressed in this staff report for City Council consideration.

Planning Commission Hearing
The Planning Commission held a public hearing on April 27, 20264, to consider the Draft Safety and Noise Element and the Draft Infrastructure, Services, and Facilities Element Update to the City's Vista 2035 General Plan. Staff presented an overview of the update process, key substantive changes to both elements, responses to public comments received during the comment period, and findings from State agencies. The Planning Commission recommended approval by a 7-0 vote.

Staff provided an overview of the five public comments letters submitted via email (Attachment 4), also provided at places, and discussed how the draft elements address those comments and identify proposed edits to address remaining gaps. There were no verbal public comments submitted during this hearing.

Staff also incorporated comments from the Planning Commission, which included minor edits to existing policies regarding vegetation buffers along freeways, strengthened word choices throughout both elements, and updates to the Noise section narrative reflecting current conditions at Palo Alto Airport. All Planning Commission comments were reviewed and incorporated into the final drafts presented for adoption.

Review by Other Agencies
The draft Safety Element was circulated to the following responsible State agencies for review, as required by California Government Code Section 65302.5:
 California Geological Survey (CGS): All Safety Elements must be submitted to CGS for review prior to adoption. CGS reviews the Safety Element for adequacy of coverage of seismic, geologic, and related hazards.
 Governor's Office of Emergency Services (Cal OES): Safety Elements must be submitted

4 Staff report: https://d3n9y02raazwpg.cloudfront.net/cityofepa/8c6faf4d-f27a-11f0-bb28-005056a89546- 29a637e7-42e3-4737-b76d-b5307e52bbc0-1776988937.pdf
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to Cal OES for review. Cal OES reviews the Safety Element for consistency with the jurisdiction's Local Hazard Mitigation Plan (LHMP). Confirmation from Cal OES that the Safety Element appropriately integrates the LHMP ensures the jurisdiction remains eligible for California Disaster Assistance Act (CDAA) funding.

Cal OES responded with a compliance checklist stating that the City meets most of the following requirements with some final steps pending adoption:
 A current, FEMA-approved or approvable pending adoption (APA) LHMP (done)  Formally adopted the LHMP via resolution (done)
 Included language within the Safety Element of your General Plan that references your LHMP (pending adoption of the Safety and Noise Element)  Included a web link, appendix, or language within the Safety Element that directs the public to the most current, approved LHMP in its entirety (done)  E-mailed the link to the updated General Plan Safety Element web page along with the signed, adoption resolution(s) to the Cal OES Mitigation Planning inbox (pending adoption)
Once the updated Safety and Noise Element has been adopted, Cal OES will review for compliance.

Fiscal Impact
Preparation of the updates is funded through the General Fund FY24-25 and FY25-26 budget.

A General Plan Update surcharge for future large projects will help offset costs related to this General Plan Element update. An additional funding source from the CSCI grant was awarded to the City to support enhanced community engagement activities.

Public Notice
Public notice was provided via posting on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto. A notice was also published in the Palo Alto Daily News on May 22, 2026. The Public Draft was made available on March 25, 2026, on the City’s website, PREP website, and email notices were sent out notifying the public of the comment period.

Environmental
The proposed project is exempt as a common-sense exemption under State CEQA Guidelines Section 15061(b)(3). This exemption applies because the proposed project does not have the potential to cause a significant effect on the environment.

The Safety and Noise Element and ISF Element update qualify for a CEQA exemption under the common-sense exemption set forth in CEQA Guidelines Section 15061(b)(3). This exemption applies where it can be seen with certainty that there is no possibility the activity may have a significant effect on the environment. The CEQA Notice of Exemption Memorandum is attached 141
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as Exhibit A. Key findings include:
 The Safety and Noise Element and ISF Element update is a program-level policy document establishing a framework for addressing hazards and does not commit the jurisdiction to any specific development action.
 The update does not include land use or zoning changes, does not increase development potential, and does not grant entitlements for development projects.  No provisions of the update would result in direct or indirect population growth or place additional demands on natural resources, public services, or infrastructure.  Future implementation actions that could affect the environment, such as code amendments, capital projects, or other physical improvements, would be subject to separate CEQA review at the time they are prepared, as applicable.

Following adoption of the Safety and Noise Element and ISF Element, staff will file the Notice of Exemption with the San Mateo County Clerk and post it with the State Clearinghouse, as required.

Government Code § 84308
Applicability of Levine Act: The approval of this does not require approval of an entitlement; therefore, the Levine Act does not apply.

Analysis of Levine Act Compliance: Not applicable.

Attachments

1. Resolution.

2. 2026 Draft Safety and Noise Element (tracked changes)

3. 2026 Draft Infrastructure, Services, and Facilities Element (tracked changes)

4. Public Comments

5. Public Comment Matrix
Exhibits
A. CEQA Notice of Exemption Memorandum
B. CEQA Notice of Exemption
C. 2026 Draft Safety and Noise Element (clean)
D. 2026 Draft Infrastructure, Services, and Facilities Element (clean) E. Appendix A Draft Background Report
F. Appendix B Climate Change Vulnerability Assessment
G. PREP Community Report
H. 5/22/26 Joint Letter
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Resolution No. XX-2026 1 of 3
RESOLUTION NO. ___– 2026

A RESOLUTION OF THE CITY COUNCIL OF EAST PALO ALTO ADOPTING AN AMENDMENT TO THE EAST PALO ALTO VISTA GENERAL PLAN 2035 TO UPDATE THE SAFETY AND NOISE

ELEMENT AND THE INFRASTRUCTURE, SERVICES, AND FACILITIES ELEMENT, , AND

MAKING REQUIRED FINDINGS UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT WHEREAS, pursuant to California Government Code Section 65300, each city and county in California must adopt a comprehensive, long-term general plan addressing the physical development of the county or city, and any land outside its boundaries which in the agency’s judgment bears relation to its planning; and
WHEREAS, The City of East Palo Alto Vista 2035 General Plan was adopted by the City Council in 2016 by Resolution 4785 and has been amended as needed; and WHEREAS, California Government Code Section 65302 identifies seven mandatory elements which all city and county general plans must include (land use, circulation, conservation, open space, noise, safety, and housing); and
WHEREAS, California Government Code Section 65302(g)(4) requires that local agencies update their general plan safety element to address climate adaptation and resiliency, and California Government Code Section 65302(g)(5) requires that local agencies update their general plan Safety Element to identify residential developments in any hazard area identified in the Safety Element that do not have at least two emergency evacuation routes; and WHEREAS, California Government Code Section 65302(g)(5) and Senate Bill 99 (2019) require that local agencies identify residential developments in any hazard area that do not have at least two emergency evacuation routes; and
WHEREAS, Government Code Section 65302(g)(6) requires that the City review the Safety Element and update it as needed upon updates to the Housing Element or Local Hazard Mitigation Plan, or at least once every eight years; and
WHEREAS, Government Code Section 65302.6 (added by AB 2140 in 2006) expressly authorizes a city or county to adopt a local hazard mitigation plan — including a multijurisdictional plan prepared in accordance with the federal Disaster Mitigation Act of 2000 (42 U.S.C. § 5165) — into its Safety Element by reference
WHEREAS, The updated Safety and Noise Element of the General Plan 2035 integrates and incorporates by reference the San Mateo County Multijurisdictional Local Hazard Mitigation Plan (MJLHMP), including the City of East Palo Alto Annex, approved by the Federal Emergency Management Agency, in accordance with California Government Code Sections 8685.9, 65302, and 65302.6, thereby maintaining the City’s eligibility for increased disaster relief funding from the State; and
WHEREAS, the City of East Palo Alto determined the proposed amendments to the Safety Element are subject to the requirements of the California Environmental Quality Act (“CEQA”) and its implementing regulations (CEQA Guidelines) as the proposed project is exempt as a common-sense exemption under State CEQA Guidelines Section 15061(b)(3). This exemption applies because the proposed project does not have the potential to cause a significant effect on the environment; and 143
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WHEREAS, pursuant to Government Code Sections 65352 through 65352.5 the City of East Palo Alto mailed a public notice to all applicable agencies including California Native American tribes provided by the Native American Heritage Commission and other entities; and WHEREAS, the Safety Element and Noise Element was developed in consultation with emergency service providers and members of the public, was reviewed by the California Governor’s Office of Emergency Services and California Geological Survey and incorporates recommendations from these agencies pursuant to Government Code Section 65302.5, and reflects best practices outlined in the State’s General Plan Guidelines and Technical Advisories; and WHEREAS, there have been numerous opportunities for members of the public to participate in the development of the Safety Element and Noise Element update, including in-person and virtual workshops, online surveys, focus group and service provider discussions; and WHEREAS, on April 27, 2026, the City of East Palo Alto Planning Commission conducted a duly noticed public hearing and recommended that the City Council adopt an amendment to the East Palo Alto Vista General Plan 2035 to update the Safety and Noise Element and the Infrastructure, Services, and Facilities Element, and to comply with recent changes to State law, incorporate the San Mateo County Multijurisdictional Local Hazard Mitigation Plan by reference into the Safety and Noise Element, and making required findings under the California Environmental Quality Act; and WHEREAS, on June 2, 2026, the City of East Palo Alto City Council conducted a duly noticed public hearing with careful consideration of all maps, facts, exhibits, correspondents, testimony, and other evidence submitted in this matter pursuant to Government Code Section 65353; and WHEREAS, pursuant to Section 18.114.070(A) of the East Palo Alto Municipal Code, if the City Council approves the Planning Commission’s recommendation the amendment to the General Plan (Vista 2035) will become effective 30 days thereafter

NOW, THEREFORE, BE IT RESOLVED 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. The proposed amendments—to add a new Safety Element (with the MJLHMP incorporated by reference) and Noise Element—will not be detrimental to the public interest, health, safety, convenience or welfare of the City.

3. The Safety and Noise Element is in the public interest and furthers the City’s responsibility to protect public health, safety, and welfare.

4. The Planning Commission has reviewed the Notice of Exemption and its findings.

5. The Safety Element is internally consistent with other elements of the City of East Palo Vista 2035 General Plan (Government Code Section 65300.5).

6. The Safety Element otherwise complies with applicable law, including without limitation:
a. The Safety Element addresses all mandatory hazard topics, including seismic, geologic, flooding, wildfire, climate change, and dam failure hazards (Gov. Code § 65302(g)(1)– (3)).
b. The Safety Element includes a climate change vulnerability assessment and adaptation and resilience goals, policies, and objectives (Gov. Code § 65302(g)(4) (SB 379, 2015)) c. The Safety Element identifies residential developments in hazard areas lacking at least two emergency evacuation routes (Gov. Code § 65302(g)(5) (SB 99, 2019)). 144
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d. The Safety Element identifies evacuation routes, their capacity, safety, and viability, and evacuation locations (Gov. Code § 65302.15 (AB 747, 2019; AB 1409, 2021)). e. The Safety Element identifies areas vulnerable to extreme heat, assesses risks, and includes responsive goals/policies (if applicable before Jan. 1, 2028)(Gov. Code § 65302.01 (AB 2684, 2024)).
f. The Safety Element incorporates the LHMP (here, the San Mateo County MJLHMP) by reference, and the LHMP is FEMA-approved (Gov. Code § 65302.6 (AB 2140, 2006); 42 U.S.C. § 5165 (Disaster Mitigation Act of 2000)).
g. The Safety Element Environmental justice considerations are addressed, either within the safety element or in coordination with a standalone or integrated environmental justice element (Gov. Code § 65302(h) (SB 1000, 2016)).

7. The Noise Element addresses all required topics, including noise contours, standards, and land use compatibility.

BE IT FURTHER RESOLVED that the City Council finds that the Safety and Noise Element and Infrastructure, Services, and Facilities Element is consistent with the certified General Plan Environmental Impact Report, and that the proposed action is exempt from the California Environmental Quality Act Guidelines Sections 15061(b)(3).

BE IT FURTHER RESOLVED that the City Council adopts a General Plan Amendment to the Safety and Noise Element and Infrastructure, Services, and Noise Element.

PASSED AND ADOPTED this 2
th day of June 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

Webster Lincoln, Mayor
ATTEST: APPROVED AS TO FORM:

James Colin, City Clerk John D. Lê, City Attorney
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10. Safety and Noise
Overview
Protecting people and property from a variety of hazards (both natural and human-made) is one of the key
missions of any city. Like many communities in the Bay
Area, tThe residents of East Palo Alto face risks from such natural and human-caused hazards like as flooding,
extreme heat, severe weather, drought, wildfire, seismic events like earthquakes, sea level rise, and contaminated soils and groundwater. Climate change is expected to
intensify many of these hazards, requiring proactive
planning and adaptation.

Cities East Palo Alto willcan take action to be more
prepared for the dangers posed by natural hazards and
more resilient when such unpredictable events occur.

This element sets forth broad goals and , policies, and actions to reduce harm to people and property from
natural and human-made hazards as well as allow the
community to be more and promote resiliencet when
such events occur. For each action, this element
identifies a relative timeframe for implementation.

Actions that correspond to current City Council priorities, including ensuring public safety, improving livability, and preparing the City for disasters and emergencies, are
labeled as short-term items to be implemented in the
near future.

This Element addresses these topics:
• Emergency Preparedness and Response
• Flooding
• Sea Level Rise
• Seismic and Geologic Hazards
• Fire Hazards
• Air Quality and Public Health
• Severe Weather
• Drought
• Extreme Heat
• Hazardous Materials
• Transportation Hazards
• Noise
In addition, area roadways and nearby airports expose
East Palo Alto residents to high and potentially unhealthy noise levels. The Safety and Noise Element identifies
major factors of concern as well as the City’s goals and policies intended to reduce risks to people and property.

For greater detail on the topics included in the Safety and Noise Element, refer to the Background Report
(Appendix A).

Climate Change Vulnerability
Climate change is one of the most significant challenges facing East Palo Alto. Rising global temperatures are
causing more frequent and intense heat waves, storms,
droughts, wildfires, and other hazards. These events
frequently occur concurrently, resulting in cascading
impacts that are progressively more difficult to manage, such as droughts amplifying wildfire risk or extreme heat exacerbating water scarcity. For East Palo Alto, climate change is expected to cause substantial shifts in hazard patterns, including more intense storms with heavier
precipitation, increased frequency and severity of
extreme heat events, rising sea levels that will expand flood-prone areas throughout the city, and emergent
groundwater that will cause flooding from below and
increase exposure risk from contamination buried in the ground.

East Palo Alto’s Vulnerability Assessment identifies
several key climate-related hazards that pose significant risks to the community. The Vulnerability Assessment
process follows the methodology outlined in the
California Adaptation Planning Guide, examining
exposure, sensitivity, potential impacts, and adaptive
capacity for various populations and community assets.

This approach ensures that East Palo Alto’s safety
planning is grounded in the best available data and
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projections, including information from Cal-Adapt, the
California Adaptation Planning Guide, and the San Mateo County Multi-jurisdictional Hazard Mitigation Plan. East Palo Alto’'s Vulnerability Assessment reveals that the
hazards posing the greatest risk to the community
include flooding, severe weather, and extreme heat.

However, these climate impacts will not affect all
residents equally. Low-resourced households,
communities of color, immigrant communities, older
adults, and persons with disabilities are among the
populations most vulnerable to climate change hazards.

These groups often face barriers such as limited financial resources for home improvements, language barriers
that hinder access to emergency information, and
housing in areas with inadequate infrastructure or
limited tree canopy coverage. East Palo Alto’'s residents have long been on the front lines of climate change and environmental justice issues, as the city is a densely
populated, ethnically diverse community with a median
income lower than San Mateo County’s average.

Recognizing these disparities, this Safety Element
prioritizes equitable adaptation strategies that protect the most vulnerable community members while building
overall community resilience. The full results of the
Vulnerability Assessment are available in Appendix B.

Statutory Requirements
California law requires that a general plan include
elements (or chapters) specifically addressing both safety and noise. This element was prepared to meet these
requirements (Government Code Sections 65302(f) and
65302(g)).

The safety section of the element must contain goals and policies to address seismic risks, including ground
shaking, landslides, tsunami and seiche; flooding; fire; climate change; evacuation routes; and water supply
requirements. AdditionalThese requirements include:
• Climate adaptation and resilience strategies based
on a Vulnerability Assessment, as required by Senate
Bill 379 (2015).
• Identification of residential developments with
fewer than two emergency access routes and
analysis of evacuation capacity, as required by
Senate Bill 99 (2019) and Assembly Bill 747 (2019).
• Evaluation of flood risks and policies to minimize
flood risks to new development, as required by
Assembly Bill 162 (2007).

As required by Senate Bill 1000 (2016), this General Plan includes an Environmental Justice Element to address
the unique or compounded health risks in disadvantaged
communities by reducing pollution exposure, increasing
community assets, and improving overall health.

California law defines environmental justice as “the fair treatment and meaningful involvement of all people
regardless of race, color, national origin or income, with respect to the development, adoption, implementation,
and enforcement of environmental laws, regulations, and policies”. Many environmental justice issues—such as
pollution exposure, access to safe homes, and access to effective public services—are closely connected to safety concerns addressed in this element. The goals and
policies in this Safety and Noise Element work in
coordination with the Environmental Justice Element to
ensure that safety planning addresses the
disproportionate risks faced by East Palo Alto’s most
vulnerable communities.

The San Mateo County Multi-jurisdictional Local Hazard
Mitigation Plan (MJLHMP) assesses the risks of hazards
Cascading and Compounding Effects
Cascading Effects: When an extreme event
causes a series of secondary events that are
larger than the initial impact.

Compounding Effects: When multiple hazards
or drivers occur simultaneously, amplifying their
collective impact.

Source: IPCC. 2019. Extremes, Abrupt Changes and
Managing Risk.
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and vulnerabilities from natural and human-caused
hazards. The MJLHMP identifies short-term (five-year)
mitigation actions to reduce these risks. It includes a dedicated annex for East Palo Alto, which specifies the community’s characteristics and history, development
trends, hazard mitigation capabilities, integration with other hazard mitigation planning efforts, and
vulnerabilities of specific facilities and infrastructure. San Mateo County led the development of the MJLHMP in
partnership with all incorporated communities, including East Palo Alto, and a number of special districts, in
accordance with the federal Disaster Mitigation Act of
2000 and the Federal Emergency Management Agency’s
(FEMA) hazard mitigation assistance guidance. This
Safety and Noise Element incorporates by reference the
current San Mateo County Multi-jurisdictional Local
Hazard Mitigation Plan and East Palo Alto Annex, as
permitted by Government Code Section 65302.6. It is
available online at https://www.smcgov.org/ceo/2021-
multijurisdictional-lhmp.

This Safety and Noise Element also integrates with the
City’s 2030 Climate Action Plan and Adaptation
Strategies, which outlines strategies at both the
municipal and community-wide level to mitigate and
adapt to climate change. The Climate Action Plan
addresses energy efficiency, renewable energy use,
material reuse and recycling, public transportation,
bicycle and pedestrian facilities, urban green spaces, and compact development patterns as important strategies in reducing greenhouse gas emissions. The plan also
includes adaptation measures for flooding, sea level rise, and other climate-related hazards that threaten the
community.

The noise section of the element must identify and
appraise noise problems in the community from a variety of sources, establish a land use pattern that minimizes exposure of residents to excessive noise, and include
possible solutions to address existing and foreseeable
noise problems.

Issues and Opportunities
Safety
Emergency Services and Preparedness
The City of East Palo Alto employs a multipronged
approach for mitigating, responding to, and recovering
from emergencies, integrating local police and fire
services with county-wide emergency management
systems and regional coordination efforts. This
comprehensive emergency preparedness framework
addresses the diverse natural and human-caused hazards
that can affect the community, from earthquakes and
flooding to hazardous materials incidents and severe
weather events.

Police Services
The East Palo Alto Police Department is led by the Chief of Police who manages a staff of (2) Captains, (4)
Sergeants, (3) CSO's, (8) Civilians, (2) Recruits and (25) Officers / Detectives. There was a total of 1,590 Group A Offenses per the National Incident-Based Reporting
System (NIBRS) in East Palo Alto in 2024 and a total of 1,634 Group A Offenses per NIBRS in 2023, resulting in a –3% change between these years. In 2023, 170 of the
crimes were classified by NIBRS as violent crimes and in 2024 171 of the crimes were classified as violent.

The East Palo Alto Police Department plays a crucial role in emergency response coordination, working closely
with the Menlo Park Fire Protection District (MPFPD), the San Mateo County Department of Emergency
Management, and emergency responders in neighboring
communities. During emergency evacuations, Police
Department officers lead evacuation efforts to ensure
they are conducted as quickly and safely as possible.

Fire and Emergency Medical Services
The City of East Palo Alto receives fire and emergency
services through MPFPD, which has seven stations and
serves the Cities of Atherton and Menlo Park and other
portions of unincorporated San Mateo County. MPFPD
provides a comprehensive array of life safety services to East Palo Alto, including fire prevention, inspection, and investigation, as well as firefighting, hazardous materials response, search-and-rescue, and paramedic services.
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MPFPD operates with 150 personnel, responding to
approximately 11,000 calls for service annually. Staff at Station 2, which is in East Palo Alto, respond to
approximately 2,000 incidents annually, comprising
about one quarter of all of MPFPD’s annual emergency
responses, with more than half of annual calls being
medical emergencies. MPFPD reconstructed Station 2
starting in 2012 as an essential service building, designed to withstand and continue operating throughout any
type of major emergency.

For immediate response, at least 33 personnel are on
duty across MPFPD’s service territory at all times,
including two Battalion Chiefs responsible for
commanding incidents and relieving company officers
during multicompany emergency operations. Each
station provides at least one heavy fire engine and is
continuously staffed by at least three crew members.

MPFPD maintains seven engine fire companies, two
Truck/Ladder Companies, one EMS Rescue, one Type 1
Heavy Rescue Unit, and several water rescue crafts,
including airboat, rigid bottom inflatable boat, and jet skis. MPFPD also sponsors Federal Emergency
Management Agency (FEMA) Urban Search and Rescue
Team Task Force 3.

Emergency Alert and Communication Systems
East Palo Alto uses multiple emergency alert systems to ensure comprehensive communication with residents
during emergencies. SMC Alert serves as the primary
alert system, used by numerous San Mateo County
agencies to issue flood, fire, severe weather, or tsunami warnings; notify the community about emergency
shelter locations; provide information about evacuation routes; and activate special teams such as Community
Emergency Response Team (CERT) volunteers. The
system was upgraded in December 2022 with Rave
Mobile Safety as the new alerting platform. Community
members can receive alerts via email, cell phone, and
voice message to landline phones, with alerts available in multiple languages, including English, Spanish, and
Filipino.

Additional alert systems include Wireless Emergency
Alerts (WEAs), which broadcast short emergency
messages from authorized public alerting authorities to mobile devices in targeted areas, and the Genasys app
(formerly Zonehaven), which provides evacuation zone
mapping and real-time evacuation orders.

Evacuation Planning and Emergency Operations
The City supports community preparedness through
various volunteer programs, including CERT volunteers
trained by the MPFPD. San Mateo County’s Coastside
Emergency Corps provides additional volunteer support
for public safety and health efforts during emergencies, with specialized training in CERT, Ham radio, medical
response, large animal evacuation, Incident Command
System and Emergency Operations Center activities, and
Red Cross shelter operations.

Currently, there is no standardized county-wide
evacuation plan and East Palo Alto does not have a
publicly available evacuation plan. However, the City is participating in the county-wide All-Hazards Evacuation Plan, which began in 2024 and is expected to finish in
2026. This comprehensive study, led by the San Mateo
County Department of Emergency Management, will
analyze potential evacuation scenarios across San Mateo County, identify potential evacuation routes, and
recommend improvements to meet State requirements
under California Government Code Section 65302.15 also
referred to as Assembly Bill 747.

In the interim, City staff have identified primary
evacuation routes, including Highway 101, State Route
84 (Bayfront Expressway and Dumbarton Bridge), Pulgas
Avenue, Bay Road/Newbridge Street, University Avenue,
and Bayshore Road. Parts of East Palo Alto lack access to multiple evacuation routes and have only a single point of ingress and egress in their neighborhood or
community. Some emergencies, such as floods or fallen
trees from high winds, may cut off these single points of access. If this happens, community members may be
unable to evacuate, and emergency responders may not
be able to reach all people needing help. The project
team identified the residential parcels in East Palo Alto that can only be accessed through a single point, as
required by California Government Code Section
65302(g)(5) (also referred to as Senate Bill 99). Figure 10- 1 shows these evacuation-constrained residential
parcels, which are concentrated in several areas of the city. The largest concentration is on dead-end streets off University Avenue near the intersection with Bay Road.
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These parcels have a single point of ingress and egress due to their location on cul-de-sacs, dead-end streets, or streets with limited connections to the broader road
network. Through the policies in this element and the
ongoing All-Hazards Evacuation Plan, East Palo Alto will take steps to better ensure safe, timely, and thorough
evacuations if needed.
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Figure 10-1: Residential Parcels with a Single Point of Ingress and Egress 151
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Regional and County Coordination
East Palo Alto participates in extensive regional
emergency management coordination through San
Mateo County’s emergency management structure.

The County Department of Emergency Management
(DEM) coordinates countywide preparedness,
response, and protection services. DEM develops
and maintains plans and procedures for all
jurisdictions, conducts exercises to evaluate
operational capabilities, and activates the County
Emergency Operations Center to support local
jurisdictions during significant incidents.

The San Mateo County Operational Area Emergency
Services Council, composed of all local governments
in the county, provides coordinated plans for the
protection of people and property during
emergencies. East Palo Alto also benefits from
mutual-aid agreements through the California
Disaster and Civic Defense Master Mutual Aid
Agreement.

Goals and Policies
Goal SN-11. Provide efficient and
effective emergency response in the
immediate aftermath of a natural or
human caused disaster.

Intent: To ensure a safe and timely response by City
residents and services during emergency events.

Policies:

15.1 Community preparedness. Reduce harm from
natural hazards by promoting a culture of
preparedness in the community through
regular, localized emergency preparedness
training programs that include practice drills
and scenario-based exercises. Provide public
education relating to seismic and flooding
hazardsto help residents be more responsive
to seismic and flooding events when they
occur. Provide public education relating to
these hazards.

15.2 Hazard mitigation planning. Continue to
participate in Local Hazard Mitigation Planning
through the Association of Bay Area
Governments (ABAG), San Mateo Office of
Emergency Services, FEMA, and surrounding
jurisdictions. Incorporate the San Mateo
Multi-jurisdictional Local Hazard Mitigation
Plan and the East Palo Alto Annex, as
approved by the Federal Emergency
Management Agency, into this Safety and
Noise Element by reference, as permitted by
California Government Code Section 65302.6.

15.3 Risk evaluation. Encourage business and
property owners to evaluate and minimize
their risks to fire, flooding, and other hazards.

15.4 Emergency access routes. Collaborate with
surrounding jurisdictions, emergency
responders, and Caltrans to ensure the
ongoing maintenance and readiness of
potential evacuation routes serving East Palo
Alto.Ensure the City’s designated system of
emergency access routes is coordinated with
regional activities for both emergency
operations and evacuation.

15.5 Fire suppression. Ensure potable water and
water for fire suppression can be available in
an emergency.

51.56 Reconstruction. Following a major disaster,
ensure expedient, sound, and equitable
reconstruction of the affected community
through measures such as development of a
Pre-Disaster and Recovery Action Plan that
focus on community resilience, sustainability,
and an evaluation for redevelopment
potential following a major disaster.

15.67 Partnerships for disasters. Promote
partnerships between the City andwith
government and nongovernmental agencies,
including public/private partnerships, to
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ensure support is ready to step in after a
disaster.

15.78 Coordinated emergency response. Ensure
Ccoordinated emergency response with the
Menlo Park Fire Protection District, major
transportation agencies, and adjacent
jurisdictions.

15.8 Promote Community Preparedness. Support
and promote community preparedness
groups, Community Emergency Response
Teams (CERT) with Menlo Park Fire Protection
District, and other preparedness training for
residents and businesses.

15.9 Preparation Assistance. In partnership with
community-based organizations, provide
financial and labor assistance to help
community members prepare for disaster
conditions, emphasizing the needs of lowresourced community members, older adults, and persons with access and functional
needs.

15.10 Safety Ambassadors. Explore creating a paid
Safety Ambassador program to support efforts
by local experts to improve community
resilience.

15.11 Location of Critical Facilities. Locate critical
facilities outside of identified hazard areas
(see Figures 10-2 through 10-10) and in areas
easily accessible by transit whenever possible,
accounting for how climate change may
increase the frequency and intensity of
hazards. If critical facilities must be in hazard
areas, continue to ensure these facilities and
their access routes are protected from the
hazard risks characteristic to each
location. This includes constructing these
facilities to standards necessary to maintain
operations during and after disaster events.

15.12 Community Resilience Centers. Coordinate
with surrounding jurisdictions, school districts,
recreation and park districts, and communitybased organizations to establish and maintain a network of equitably located emergency
shelters, community resilience centers, and
alternate care sites that provide emergency
resources and services throughout the
community.

15.13 Flexible-Use Public Facilities. Ensure the
designs for new and significantly renovated
community-oriented City facilities allow for
flexible uses and support multiple community
purposes, including being used as community
resilience centers.

15.14 Resilient City Facilities. Renovate existing Cityowned facilities and design new City facilities to incorporate renewable energy generation
systems, battery energy storage systems, and
energy-efficient design and features, as
feasible.

15.15 Coordinated Evacuation Efforts. Coordinate
with transit agencies, school districts,
community service organizations, and faithbased organizations to assist with evacuation efforts, ensuring evacuation services are
available to vulnerable populations, including
those with limited English proficiency, limited
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mobility, or limited access to transportation,
communication, and other lifeline resources
and services.

15.16 Emergency Operations Plan. Maintain an
Emergency Operations Plan that meets
current and anticipated community needs in
the event of a major disaster or hazardous
event and conforms with the California
Standardized Emergency Management System
(SEMS).

15.17 Emergency Alert Systems. Ensure emergency
alert systems provide community members
with alerts about upcoming or current
emergency events in languages and formats
accessible to the entire community. Use
diverse outreach methods and partner with
trusted community organizations to continue
to increase enrollment rates and reach all
segments of the community.

15.18 Mutual Aid Coordination. Continue to
coordinate with the emergency service and
medical service providers to ensure
preparedness and provide emergency
response.

15.19 Recovery Educational Materials. Ensure that
communication, education, and information
materials on short-term recovery activities are
available to all residents with a focus on
accessibility for vulnerable populations.

15.20 Visitor and Tourist Emergency Management.

Develop protocols for managing non-resident
populations during emergency events,
including evacuation procedures, resource
allocation planning, and coordination with
local businesses to ensure sufficient
emergency response capacity.

15.21 Equitable Emergency Response. Work with
emergency service providers to ensure
response times and service levels in East Palo
Alto are comparable to surrounding
communities, with regular monitoring and
reporting of response time data.

Seismic Risks and Soil-Related Hazards
Earthquakes
As in most of the San Francisco Bay Area, seismic
events are considered a fact of life in East Palo Alto; more of a “when” than an “if”. Earthquakes cannot
be reliably predicted or avoided, but communities
like East Palo Alto can be prepared to face these risks and create a plan/establish policies to ensure the
resilience of the community.

The United States Geological Survey (USGS)
considers most of the San Francisco Bay Area,
including all of San Mateo County, to be at very high
risk of experiencing a major earthquake within the
next 50 years. As shown in Figure 10-2, East Palo
Alto’s proximity to several active faults— including
the San Jose Fault (shown in Figure 10-2) Hayward
Fault (10 miles east), San Andreas Fault (7 miles
west), and the San Gregorio Fault (20 miles west)—
represents a significant factor in planning for a safer future.

Geologists use the terms “magnitude” and
“intensity” to describe and measure the degree of
ground shaking in an earthquake. Magnitude
measures the amount of energy released by an
earthquake. Intensity is a more subjective measure
of effects that people can perceive or see.

Magnitude and intensity form the basis of the
Modified Mercalli Intensity Scale (MMI). The MMI is
a scale of 1 to 12 (I to XII) with higher numbers
representing higher intensity. For reference, the
1906 San Francisco earthquake (whose epicenter
was located in Marin County) is estimated to have
resulted in an MMI of VII to VIII in East Palo Alto. The 1989 Loma Prieta earthquake (whose epicenter was
in the Santa Cruz Mountains) registered an MMI of
VIII in East Palo Alto.
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As shown in Figure 10-1, all of East Palo Alto would
experience severe ground shaking in a large
earthquake. The USGS predicts that the San Andreas
Fault has a 21 percent chance, the Hayward Fault
has a 31 percent chance, and the San Gregorio Fault
has a 6 percent chance of producing a magnitude

6.7 or greater earthquake in the next 30 years. There
is no data for the San Jose quaternary fault. USGS
predicts a 63% probability that the Bay Area will
experience a magnitude 6.7 or greater earthquake
before the year 2036. Of all Bay Area faults, USGS
predicts that the San Andreas, Hayward, and
Rodgers Creek faults have the greatest probability of
activity. None of these faults run directly through
East Palo Alto, reducing the potential for direct
surface fault rupture. Surface rupture occurs when
fault movement during an earthquake literally
breaks or ruptures the ground. However, a major
earthquake on one of these faults would still cause
severe ground shaking throughout East Palo Alto,
potentially triggering secondary hazards such as
liquefaction, landslides, and infrastructure damage.

Therefore, East Palo Alto’s proximity to several
known active faults represents an important factor
in planning for a safer future.

Past Seismic Events
The last significant earthquake in the Bay Area was
the magnitude 7.1 Loma Prieta earthquake in 1989,
which caused significant damage throughout the
region. Other notable earthquakes include the 1906
San Francisco earthquake (magnitude 7.8) and the
2014 South Napa earthquake (magnitude 6.0). The
region has experienced multiple moderate
earthquakes (magnitude 5.0-5.9) in recent decades.
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Figure 10-2: Local Faults
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Liquefaction
East Palo Alto’s location makes it particularly susceptible to liquefaction. Liquefaction occurs when soils take on liquidlike qualities during a seismic event. Rising
groundwater levels driven by sea level rise and increased precipitation can further elevate liquefaction risk by
raising the water table closer to the surface and
increasing soil saturation. A key consequence of
liquefaction is ground failure. Ground failure occurs
when the soil loses its load-bearing capacity, causing
buildings and foundations to sink or settle unevenly,
underground infrastructure to destabilize, and roadways and utilities to buckle or break. This can have serious implications for older structures that were built before state and local building codes were updated (in the early 1970s) to be more resilient against seismic and soilsrelated hazards. As shown in Figure 10-110-23, the areas at greatest all of East Palo Alto is at risk of liquefaction are the baylands areas as well as the area along US
101/San Francisquito Creek.

Tsunami and Seiche
Coastal and shoreline portions of California must
consider the potential for tsunamis and seiches.

Tsunamis, like the surges generated by the March 11,
2011, Tōhoku earthquake in northeastern Japan, resulted in substantial damage to harbors in Crescent City and
Santa Cruz. As shown in Figure 10-34, East Palo Alto’s
position within San Francisco Bay limits the potential for tsunami damage, but sea surgestsunami waves may
impact areas of the cCity directly adjacent to the bBay.

The California Department of Conservation has identified the area around Ravenswood Slough and Cooley Landing
as potential tsunami inundation areas.

Seiches are another bBay-related seismic hazard. Seiches are earthquake-generated waves within an enclosed
body of water like a lake or a reservoir. East Palo Alto lacks major enclosed bodies of water, but seiche risks
within the Bay need to be considered in
planningshoreline areas of the community are at risk of inundation from a seiche.

Figure 10-2 shows the inundation resulting from a
tsunami or seiche. Dam Failure
Dam failure - resulting from seismic or other causes - is another potential natural hazard. The failure of a dam
can result in swift flooding and inundation of
downstream areas, potentially causing harm to people
and property within the path of released waters. San
Mateo County has mapped areas susceptible to the
failure of dams located in or near the County. The
County has identified the Searsville Dam, which
impounds a creek tributary to San Francisquito Creek, as posing a potential dam failure hazard to portions of the Stanford campus, the City of Palo Alto, and the lower
reaches of San Francisquito Creek, which forms the
boundary of East Palo Alto and Palo Alto as it enters San Francisco Bay, as shown in Figure 10-2.

Soils-Related Hazards
While seismic hazards pose the most acute risk to safety in East Palo Alto, a number of other soils-related hazards can also result in harm to people and damage to
property.

Subsidence means a failure or collapse of the existing
ground surface. This is usually caused when subsurface
materials, such as groundwater, are extracted or
dissolved, which can create a subsurface void leading to a surface failure. Groundwater extraction in East Palo
Alto has been minimal, allowing groundwater recharge
to limit the potential for subsidence to occur in the
community.

Differential settlement is a type of subsidence.

Differential settlement describes a condition in which
adjacent areas of soil sink or settle at different rates.

When buildings or structures straddle lands with
differing settlement rates, the portion of the building or structure below the sinking soil can be damaged. Over
time, differential settlement can result in substantial damage to buildings and structures. Areas of East Palo
Alto built on former tidal flats – including neighborhoods along the bay shoreline, bordering San Francisquito
creek, Cooley Landing, and Ravenswood – could be
susceptible to differential settlement where low-strength native soils are immediately adjacent to loose or
unconsolidated fill.

Due to its relatively flat topography, the city faces little risk of landslides or debris flows. As shown in Figure 10- 5, there are no identified landslide hazard areas in the city.

Future Conditions
Earthquake frequency and magnitude are not expected
to change due to climate change, but climate-related
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hazards may compound the impacts of earthquakes. For
example, liquefaction risks may increase in areas where groundwater levels rise due to sea level rise, as discussed in the Emergent Groundwater section. Additionally,
seismic events could trigger secondary hazards such as
levee failures during periods of high-water levels,
potentially causing more severe flooding than would
occur from either hazard alone.

Climate change may exacerbate soil-related hazards in
East Palo Alto. Rising groundwater levels from sea level rise can increase the potential for subsidence and
differential settlement, particularly in areas with organic soils. More significantly, the combination of rising
groundwater and increased soil saturation during
extreme storms can substantially increase liquefaction
susceptibility during seismic events, especially in areas along the baylands and near San Francisquito Creek.

Rising sea levels will increase the base water level,
potentially allowing tsunami and seiche waves to reach
farther inland than currently expected. Additionally,
compound events where storms coincide with seismic
activity could create more severe flooding scenarios, and increase dam failure risks when aging infrastructure faces stress from both extreme precipitation and ground
shaking.
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Figure 10-3: Liquefaction and Ground Shaking
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Figure 10-4: Tsunami Hazard Zones
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Figure 10-5: Landslide Susceptibility
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Goal SN-12. Reduce the risk to people
and property from earthquakes and
other geologic hazards.

Intent: To lessen the impacts of earthquakes and geologic threats on City residents.

Policies:

12.1 Construction requirements. Apply the proper
development engineering and building
construction requirements and best practices,
including review by a state-licensed geologist, to
avoid or minimize risks from seismic and geologic
hazards.

12.2 Robust seismic guidance. Utilize and
enforceEnforce the most recent State guidance for
seismic and geologic hazards when evaluating
development proposals.

1.3 Licensed geologist. Require that a state licensed
engineering geologist prepare and/or review
development proposals involving grading, unstable
soils, and other hazardous conditions. Incorporate
recommendations of the geologist into design
plans, potentially including building modifications
and open space easements.

12.34 Seismic upgrades. Examine necessity of seismic
upgrades to existing public facilities, as well as
existing multi-family housing constructed prior to
1971, and existing soft-story multi-family housing.

12.454 Site-Specific Geotechnical Investigations.

Require individual site-specific geotechnical
investigations for new construction and substantial
improvement projects within liquefaction hazard
zones and tsunami-prone areas, as shown on
Figures 10-32 and 10-43, to determine the depth
of bedrock, soil stability, location of rift zones, and other localized geotechnical problems as part of
the environmental and/or development review
process for all structures.

Flooding Potential and Sea Level Rise
East Palo Alto has a history of flooding problems due to its low-lying location along the Bay, particularly in areas along San Francisquito Creek. The City has experienced
eight major flood events since 1940. Flooding occurs
when water surpasses the capacity of local water bodies to contain it, creeks to carry it, or soil to absorb it. There are five types of flooding that affect East Palo Alto:
• Riverine flooding occurs when San Francisquito
Creek overruns its banks.
• Stormwater flooding occurs when rainfall
accumulates in areas with insufficient drainage
throughout the community, especially in the
Gardens neighborhood. Flooding is worsened when
the city's shallow groundwater table is elevated from
sustained rainfall or seasonal conditions, reducing
soils' ability to absorb runoff, and when high tides or storm surge raise bay water levels and reduce the
drainage system's ability to discharge to the Bay and
San Francisquito Creek.Soils-Related Hazards
Understanding Flood Terminology
Floodplain: Areas that become inundated by high
volumes of water, usually adjacent to rivers, creeks,
lakes, or along the ocean. These areas are officially
mapped by the Federal Emergency Management
Agency (FEMA) using Digital Flood Insurance Rate
Maps (DFIRMs).
100-Year Floodplain: The area that has a 1 percent (1
in 100) chance of being flooded in any given year,
also known as a “base flood”. This does not mean
flooding occurs only once every 100 years—rather,
there is a percent probability of this level of flooding happening each year.
500-Year Floodplain: The area that has a 0.2 percent
(1 in 500) chance of being flooded in any given year.

These areas face lower probability but more severe
potential flooding than 100-year floodplains.
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While seismic hazards pose the most acute risk to
safety in East Palo Alto, a number of other soilsrelated hazards can also result in harm to people and damage to property.

Subsidence means a failure or collapse of the existing
ground surface. This is usually caused when
subsurface materials are extracted or dissolve,
which can create a subsurface void leading to a
surface failure. Subsidence can occur when
groundwater is extracted or when subsurface
organic soils decompose and shrink.

Groundwater extraction in East Palo Alto has
been minimal, allowing groundwater recharge to
limit the potential for subsidence to occur.

Differential settlement is a type of subsidence.

Differential settlement describes a condition in
which adjacent areas of soil sink or settle at
different rates. When buildings or structures
straddle lands with differing settlement rates, the
portion of the building or structure below the
sinking soil can be damaged. Typically,
differential settlement occurs slowly so that
acute harm to humans is not generally a concern.

However, over time, differential settlement can
result in substantial damage to buildings and
structures. Areas of East Palo Alto that are
comprised of former tidal flats could be
susceptible to differential settlement where lowstrength native soils are immediately adjacent to loose or unconsolidated fill.

Due to its relatively flat topography, the City faces
little risk of landslides or other seismic-related
debris flows.
• Flash floods are sudden events caused by intense
localized storms.
• Shoreline floods occur when the bay inundates
normally dry lands due to storm surges or extreme
high tides.
• Dam failure flooding can occur as a result of seismic or other causes, resulting in swift inundation of
downstream areas.

East Palo Alto has a history of flooding problems due to its low-lying location along the bay, particularly in areas along San Francisquito Creek. The city has experienced
eight major flood events since 1940, with many residents experiencing multiple flood events over their tenure in the city.

Flooding has occurred primarily as a result of high High tides, heavy rains causing high water levels flowing down thein San Francisquito Creek, and an inadequate storm
drain system are the major sources of flooding in East
Palo Alto. High tides combined with strong easterly
winds can generate storm surge or wave runup,
potentially causing widespread coastal flooding. Heavy
precipitation can also overwhelm San Francisquito
Creek’s capacity, leading to significant riverine flooding if floodwaters cannot drain effectively into the bay.High
tides combined with winds from the east that create
storm surge or wave runup could lead to widespread and
significant flooding, especially if precipitation exceeds the Creek’s capacity to carry floodwaters to the Bay. As of 2015, many of the streets in East Palo Alto lack storm drains. Where storm drains exist, they lack the capacity to handle stormwater during heavy rain events. During
10 and 20 year storm events in East Palo Alto, storm
drains can overflow, flooding the streets, and in the case of the 1998 floods, parts of the City were effectively
stranded. A heavy rain event in December 2012 led to
significant flooding in multiple parts of the City. Low-lying areas face extra risk of floods related to levee breaks, ruptures or overtopping.

Special Flood Hazard Areas
The Federal Emergency Management Agency (FEMA)
prepares a detailed technical study, known as the Flood Insurance Study, and maintains maps of floodways and
floodplains for the entire United States. FEMA maps
these areas on Flood Insurance Rate Maps (FIRM). A
typical FIRM will show Special Flood Hazard Areas (SFHA) within reach of a 100 year100-year flood, estimate the
height of floodwaters, and delineate areas subject to
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other jurisdictions use FIRMs to establish zoning districts, buffers, or other regulatory requirements intended to
protect people and property from flood damage and
minimize the cost of physical flood control mechanisms.

In East Palo Alto, the City uses FEMA flood maps to
enforce its Floodplain Management Ordinance, which
requires flood-resistant building standards in the 100- year floodplain, including mandatory elevation of
structures to 18 inches above the base flood elevation.

As illustrated in Figure 10-36, data from the relevant
FIRMs indicates that areas along the bay and near the
San Francisquito Creek face the highest flood risks during storm events and/or high tide events. The current FIRMs were adopted in 2021 and reflect historical flood
patterns. Climate change and sea level rise are expected to expand flood zones significantly beyond areas
currently mapped by FEMA, as rising Bay water levels
and more intense precipitation events increase flood
risks. To address these future hazards, the City is working with OneShoreline to use the best available sea level rise projections and identify areas vulnerable to future
flooding beyond what FEMA maps currently show.

Approximately half of the parcels in East Palo Alto are in a mapped floodplain. Based on this analysis and past
flooding incidents, the following areas within the city are particularly vulnerable to flooding:
• The Weeks and Garden Neighborhoods, east of
Pulgas Avenue.
• The Woodland Neighborhood, between San
Francisquito Creek and the Bayshore Freeway.
• The University Village Neighborhood, north of Notre
Dame Avenue.
• The portion of the Ravenswood Employment District
closest to the Baylands.;
• The Kavanaugh Neighborhood.; and
• The Palo Alto Park Neighborhood, west of Menalto
Avenue.

East Palo Alto has participated in FEMA's Community
Rating System (CRS) since 2010. CRS is a voluntary
program that recognizes and encourages community
floodplain management activities that exceed the
minimum National Flood Insurance Program (NFIP)
requirements. The CRS provides flood insurance
premium discounts to residents based on the
community’s flood mitigation and education efforts.

The CRS uses a rating scale from 1 to 10, with Class 1
representing the highest level of flood protection
activities and Class 10 indicating that the community
only meets the minimum NFIP requirements. Each CRS
class improvement results in a 5 percent discount on
flood insurance premiums for residents, with potential
savings ranging from 5 percent (Class 9) to 45 percent
(Class 1). East Palo Alto has a current CRS class rating of 7, which equates to a 10 percent flood insurance
premium discount. The City is committed to improving its CRS rating through enhanced floodplain management
activities, which will provide greater flood insurance
savings for residents while improving overall community flood resilience.While approximately 49 percent of the
City is currently located within a FEMA designated SFHA, sea level rise and climate change area likely to further expand the SFHA. As identified by the new preliminary
FIRMs published in August 2015, 56% of the City may
soon be designated as SFHA, and more by the turn of the century. The brown areas shown in Figure 10-3 have
been assigned a 0.2 percent annual chance of flooding,
known as a 500-year flood. While a much larger portion
of the City would be inundated in such a flood, it would be a very rare event.
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Figure 10-6: Flood Hazard Zone
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Dam Failure
The failure of a dam can result in swift flooding and
inundation of downstream areas, potentially causing harm to people and property in the path of released waters. San Mateo County has mapped areas susceptible to the failure of dams located in or near the county. The County has
identified the Searsville Dam, which impounds a creek
tributary to San Francisquito Creek, as posing a potential dam failure hazard to portions of the Stanford campus, the City of Palo Alto, and the lower reaches of San Francisquito Creek, which forms the boundary of East Palo Alto and Palo Alto as it enters San Francisco Bay. As shown in Figure 10-7, the city is also within the inundation area of the Felt Lake Dam. Both dams are owned by Stanford University and
have received satisfactory ratings from the California
Division of Safety of Dams. Tidal flood waters completely submerged some streets in the University Village
neighborhood in 1972.

It is important to note that many structures inside the SFHA have a much higher than one percent probability of being flooded. For instance, some areas near San
Francisquito Creek have been flooded several times in the last 60 years. It is also possible that properties outside the flood zones could be subject to flooding even though
FEMA's hydrologic models do not predict such flooding.

With this in mind, the City of East Palo Alto has taken great strides to alleviate hazards related to flooding.

Existing Action
The City has undertaken many actions and activities to
avoid or reduce flood risks. These activities include the mailing of a relevant brochure to all properties in the community on an annual basis, explaining the risks and
hazards related to flooding, and establishing benchmarks so developers have accurate elevation figures. The City also requires morehas enacted stringent building codes, such as the mandatory elevation of structures to 18 inches above the height of flood waters, which mitigate risk due to
inundation. Additionally, East Palo Alto reviews the
effectiveness of these activities annually, and provides FEMA a progress report each year that identifies action taken to reduce the potential for loss of life and damage to property. FEMA rewards voluntary actions that reduce
potential loss of life and damage to property in a flood by reducing flood insurance premiums. The City has
undertaken activities to alleviate potential flooding
hazards, which has resulted in savings on insurance
premiums. As of 2021, 941 flood insurance policies are in force in East Palo Alto and there were 32 total payouts for approximately $157,000 in losses. These policy holders pay approximately $1.04 million annually in premiums.

The City's Storm Drain Master Plan, adopted in 2015,
identified significant deficiencies in the drainage system.

Many of the streets in East Palo Alto still lack storm drains, and where they exist, they lack the capacity to handle
stormwater during heavy rain events. Over half of the city (56 percent) is in areas with elevated flood risk, and more than half of the drainage area relies on pumping from the O'Connor Pump Station, which requires near-term
improvements to maintain its existing capacity. The Master Plan identified approximately $37.5 million in needed
capital improvements, including pipe improvements,
system expansion, pump station retrofit, and other critical infrastructure upgrades. During 10- and 20- year storm
events in East Palo Alto, storm drains can overflow and flood the streets. Low-lying areas face extra risk of floods related to levee breaks, ruptures, or overtopping,
particularly when combined with overtopping from San
Francisquito Creek.

FEMA rewards voluntary actions that reduce potential loss of life and damage to property in a flood by reducing flood insurance premiums. In 2012, 910 property owners in the City paid $1,060,141 for flood insurance. Due to activities undertaken by the City to alleviate potential flooding
hazards, residents collectively received a yearly savings on insurance premiums of $174,927, or $191 per household.

San Francisquito Creek Joint Powers Authority
A proactive step the City has taken to reduce flooding risk involves joining with the cities Menlo Park and Palo Alto, along with the San Mateo County Flood Control District
and the Santa Clara Valley Water District in a Jjoint
Ppowers Aauthority (JPA) intended, formed in 1999 to
develop and maintain projects along the creek that reduce flood threats and benefit the environment. the In 2019, the JPA completed a project on the “Reach 1” section of San Francisquito Creek, which improved’s first major
project would improve the lower reaches of the creek,
from Highway 101 to the bay. The Reach 1This project
would widened the creek to better convey 100- year storm flows (also taking into account high tides and up to 26 166
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inches3 feet of sea level rise), excavated sediment from the mouth of the bBay, and constructed new floodwalls and
engineered levees. The project protects more than 1,700 properties from a 100-year creek flood during a King tide event and resulted in more than 22 acres of new or
improved marsh habitat. The City is currently working with the JPA on the Reach 2 project, which will address the next segment of the creek upstream from Highway 101.

Many bayfront areas in and near East Palo Alto feature
earthen levees intended to protect against tidal influx.

Figure 10-3 shows the incomplete system which generally follows the shoreline but also upland portions of San
Francisquito Creek. Notwithstanding that FEMA has
accredited many of the levees along the bBayfront, SFHAs are still present throughout substantial portions of the community as noted above.
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Figure 10-7: Dam Inundation
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Past Events
Significant flood events have caused substantial
damage to East Palo Alto, including:
• 1972: Tidal flood waters completely submerged
streets in the University Village neighborhood.
• February 1998: Parts of East Palo Alto
experienced significant flooding along San
Francisquito Creek, impacting more than 1,100
homes and businesses and causing over $28
million in damages. Hundreds were forced to
evacuate and major thoroughfares were closed.
• December 2012: A storm caused water to flow
over a 600-foot section of levee between
Verbena Drive and Daphne Way, forcing
evacuations for 36 residents. One home was
declared uninhabitable.
• December 2022: Heavy rains caused flooding
near San Francisquito Creek, with residents
losing belongings and incurring hundreds of
thousands of dollars in property damage.

Future Conditions
Climate change will likely cause these flood zones to
expand as sea levels rise and the tide regularly
moves farther inland (see the Sea Level Rise section
that follows and Figure 10-8). Additionally, as rising
groundwater emerges at the surface, many areas
will experience flooding from below, even in areas
that appear protected from coastal flooding (see the
Emergent Groundwater section and Figures 10-9
and 10-10). As the risk of intense storms increases,
many of these areas—which include residential
neighborhoods with schools and community-serving
facilities—could be damaged or destroyed by major
flooding. Industrial and commercial areas also face
flood risks that could cause the movement of
pollution and hazardous materials through soil and
groundwater.

Climate change is expected to increase both the
frequency and intensity of extreme precipitation
events in East Palo Alto. Warmer temperatures allow
the atmosphere to hold more moisture, leading to
more intense storms. Additionally, aging stormwater
infrastructure will face increasing stress from these
extreme events, resulting in system overflows,
infrastructure failures, loss of drainage capacity, and pump station breakdowns. The combination of more
intense rainfall, inadequate drainage capacity, and
rising bay water levels will exacerbate flood risks
throughout the community, particularly in the
vulnerable neighborhoods identified above.

Goal SN-23. Provide adequate
necessary flood control and storm
drainage facilities to minimize the
risk of flooding.

Intent: To lessen the impacts of flood events on City
residents by avoiding placing residents in harm’s
way.

Policies:

23.1 Flood Insurance Program. Continue to
participate in the National Flood Insurance
Program and FEMA’s voluntary programs, such
as the Community Rating System.

23.2 Innovative Insurance Solutions. Partner with
San Mateo County, OneShoreline, communitybased organizations, and other stakeholders to study and explore new and innovative flood
insurance approaches that increase financial
resilience for vulnerable residents, prioritizing
low-income households and renters in flood
hazard zones.

23.3 Community Rating System Improvement.

Identify and implement programs and projects
that maximize the City’s Community Rating
System (CRS) to reduce flood insurance
premiums for residents, including enhanced
floodplain management activities, public
information programs, and flood mitigation
projects. Ensure sharing of information with
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the public around these processes, their
timelines, and how they will benefit residents.

2.2 Flooding related to sea level rise. Consider
expanding boundaries of development control
particularly where sea level rise could worsen
flooding above predicted conditions.
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Figure 10-8: Sea Level Rise
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Figure 10-9: Emergent Groundwater in East Palo Alto by 2050 172
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Figure 10-10: Emergent Groundwater in East Palo Alto by 2100 173
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23.43 Development in floodways. Continue to control
minimize or restrict development in the floodway
and floodway fringe.

IM 23.34a: Require new development that impacts
floodplain areas to provide replacement flood
storage capacity, ensuring a positive gain and no net
loss of flood storage in the community.

Timeframe: Short-Term

23.54 Floodplain Management Ordinance. Continue to
enforce and consider strengthening the City’s
Floodplain Management Ordinance to protect
against changing flood hazard conditions.

IM 23.5a: Review and update the Floodplain
Management Ordinance when FEMA updates flood
maps to incorporate current FEMA guidance and
climate projections.

Timeframe: Short-Term

2.65 Location of essential public facilities. Continue to avoid placing essential services and critical facilities in areas of elevated risk of flood. If essential services and critical facilities cannot be located outside of risk zones, ensure that facilities are constructed to
appropriate standards to maintain operations during
and after disaster events

23.6 Public buildings. Work to Eenhance flood protection for essential public buildings and associated parking
areas. Specifically, considering which public buildings are at the highest risk and prioritizing infrastructure updates.

23.7 San Francisquito Creek Joint Powers Authority (JPA) and Regional Partners: Continue to work with the
JPA, OneShoreline, and other appropriate agencies
on projects that will reduce the risk of flooding in
East Palo Alto. Present this information, including
projects and timelines, in public forums like the
SAFER Bay projects, public workshops, tours, and
Advisory Group regularly to ensure residents are
informed and involved in the decisions made in
partnership with the JPA.

2.93.8 Safeguarding Underground Utilities in FloodProne Areas. Coordinate with utility providers to protect or relocate underground utility infrastructure
that is in areas prone to flooding. Identify the most
vulnerable underground utilities and prioritize
infrastructure updates by working with the relative
agencies and owners.

2.103.9 Home Hardening Against Flooding. Partner with
Community-Based Organizations to provide
educational resources, secure grants, and provide
financial assistance to low-resourced households
and rental properties in flood hazard zones to
harden homes against flooding.

IM 2.103.9a: Investigate the feasibility of
establishing a residential flood retrofit grant program prioritizing low-income households in flood-prone
areas.

Timeframe: Short-Term

23.110 Drainage and Flood Control Systems. Design and
implement integrated stormwater management
systems that combine traditional drainage
infrastructure with green infrastructure elements
(such as bioswales, rain gardens, permeable
surfaces, and larger engineered flood storage
facilities such as retention basins and holding ponds
where feasible) to improve flood control while
enhancing local ecosystems. Continue to ensure
future development is consistent with the green
infrastructure plan.

2.123.11 Drainage Improvements. Regularly
remove debris and increase the amount of
landscaped areas and other permeable surfaces in
public and private projects to improve drainage,
especially in flood-prone areas adjacent to San
Francisquito Creek and the San Francisco Bay.

IM 2.123.11a: Establish regular maintenance
schedules for City storm drain infrastructure.

Timeframe: Short-Term
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IM 2.123.11b: Update landscaping ordinances to
promote permeable surfaces in flood-prone areas.

Timeframe: Short-Term

2.133.12 Storm Drain System Upgrades.

Implement the Storm Drain Master Plan by
prioritizing capital improvements to upgrade storm
drain capacity, including pipe improvements, system
expansion, installation of new storm drains in areas
currently lacking coverage, and pump station
retrofits to handle increased stormwater volumes
and climate change impacts.

IM 3.12a: Partner with OneShoreline and other
regional agencies to support the development of a
countywide compound flooding study that models
the combined effects of future rainfall, sea level rise, and groundwater rise to identify areas of increased
flood risk. Use study findings to inform updates to
the Storm Drain Master Plan and shoreline flood
protection planning.

Timeframe: Long-Term

2.143.13 Flooding Preparation and Response. Cocreate flooding preparation and response action plans with community members to ground technical
expertise in local knowledge. Conduct community
outreach to a significant number of residents and
make sure the finished action plans are thoroughly
shared and understood throughout the community
through focus groups and workshops.

2.153.14 Flood Impact Assistance. Develop
programs to assist residents and businesses with
flood preparation and recovery, with particular focus
on historically impacted areas such as the O'Keefe
area and areas near San Francisquito Creek. This
includes emergency planning support, post-flood
cleanup assistance, and coordination with recovery
resources.

Sea Level Rise
The FIRM does not take into account potential flooding
related to sea level rise. The Bay Conservation and
Development Commission (BCDC) have mapped areas
throughout the Bay region susceptible to inundation from potential sea level rise scenarios. Figure 10-4 shows the areas along the Central Bay West Coast that BCDC has
identified as being potentially exposed to inundation
related to sea level rise. Even in the low sea level rise scenario (16 inches), substantial Bayside portions of the City would be at risk of inundation if no inundation
protections are implemented. The risk of damage from sea level rise could be lessened by the incomplete system of levees on Bayfront areas (see Figure 10-3). However, sea level rise will continue to be an important issue in long range land use planning all along San Francisco Bay as well as other low-lying areas world-wide.

As global temperatures rise, glaciers and other polar ice melt, causing sea levels to rise. High average temperatures can also cause ocean water to expand, causing further
rising of sea levels. Flooding and sea level rise create disproportionate impacts for:
• Low-resourced households lacking resources for home
repairs, weatherization, and flood- proofing.
• Older adults with reduced mobility, impaired vision,
and hearing loss who face evacuation challenges.
• Immigrant communities who may distrust government
evacuation orders due to citizenship concerns.
• Residents who are dependent on medications or
medical devices that may be lost or damaged.
• People living in older buildings with poor maintenance and structural vulnerabilities.

Affected Areas
As shown in Figure 10-87, over half of East Palo Alto is vulnerable to sea level rise impacts. The areas at greatest risk include:
• Neighborhoods north of Bay Road and east of
University Avenue
• Areas along Pulgas Avenue
• Cooley Landing and surrounding areas
• Neighborhoods near Costaño Elementary School
• The Ravenswood Slough near the Baylands
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These low-lying areas face permanent inundation from
rising water levels, contamination risk from rising
groundwater, and temporary flooding during storm events that will reach farther inland as baseline water levels increase.

Past Trends
Over the past century, water levels in San Francisco Bay have risen by eight inches. While this change has been
gradual, it has already begun to increase the frequency of nuisance flooding during high tides and has reduced the capacity of storm drainage systems during rain events.

Future Projections
According to the 2024 State of California Sea Level Rise Guidance, East Palo Alto should prepare for as much as:
• 0.4 feet (5 inches) of sea level rise by 2030
• 1.3 feet (16 inches) of sea level rise by 2050
• Up to 6.5 feet (78 inches) of sea level rise by 2100
However, sea levels could rise faster than these
projections. Storm surge and King Tide events can add an additional 24 to 36 inches of temporary flooding on top of baseline sea level rise, pushing floodwaters even farther inland.

By 2050, many neighborhoods along Pulgas Avenue, Cooley Landing, and areas near Costaño Elementary School may
be permanently inundated. This area includes nearly all schools in East Palo Alto, police stations, four government facilities and community centers, and the critical O'Connor pump station.

Sea level rise will also cause rising groundwater levels in areas away from the shoreline, as discussed in the
Emergent Groundwater section. Due to the prevalence of
contaminated sites in East Palo Alto, rising groundwater that may harbor contaminants puts residents at an
additional risk. The combined effects of permanent
inundation, more frequent flooding, and groundwater
emergence with a risk of contamination pose significant long-term challenges for community safety and resilience.

Goal SN-34. Protect the community from
sea level rise impacts through adaptive
planning, regional coordination, and
resilient infrastructure development.

Intent: To reduce risks from permanent and temporary
inundation due to sea level rise and ensure that planning and development decisions account for projected future
conditions over the life of projects.

Policies:

34.1 Flooding related to sea level rise. Apply flood
control and mitigation requirements to properties
vulnerable to sea level rise hazards as indicated on
Figure 10-78 to provide flood protection over the
lifetime of the project.

IM 34.1a: Update the Floodplain Management
Ordinance to incorporate sea level rise projections
under medium-high risk scenarios by 2100, as shown
on Figure 10-78, or the most current projections
adopted by the State of California or Bay
Conservation and Development Commission.

Timeframe: Short-Term

34.2 Sea Level Rise Vulnerability Assessment and
Adaptation Planning. In partnership with
OneShoreline, use the best- available sea level rise
projections to regularly identify the areas of the city that are vulnerable to temporary and permanent
inundation from sea level rise and related hazards by
evaluating multiple sea level rise scenarios,
establishing monitoring systems to track changing
conditions, and adjusting strategies as new scientific
information becomes available or conditions exceed
projections. Use this information to continue to
develop or adjust land use and permitting
requirements and municipal adaptation strategies.

34.3 Resilient Siting and Design for Critical Facilities. Site new critical facilities and public infrastructure in
areas that are not vulnerable to sea level rise
hazards as indicated on Figure 10-78. If new critical
facilities and public infrastructure cannot be located
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outside of areas prone to sea level rise, ensure that
facilities are constructed to appropriate standards to
maintain operations under these future conditions
over the life of the project.

IM 34.3a: Adopt siting standards requiring new
critical facilities to be located outside projected sea level rise inundation areas as shown on Figure 10-87
or based on the most current projections adopted by
the State of California or Bay Conservation and
Development Commission.

Timeframe: Short-Term

34.4 Sea Level Rise in Capital Planning. Integrate sea
level rise considerations into the planning of Capital
Improvement Projects, including siting and design
features to mitigate risk of damage or other harm.

34.5 Regional Sea Level Rise Coordination. Collaborate
with OneShoreline to develop and regularly update
standardized datasets for modeling sea level rise
impacts at both regional and local scales that
account for San Francisco Bay geomorphic features.

IM 34.5a. Participate in coordinated adaptation
planning within the same Operational Landscape
Unit as defined by the San Francisco Bay Shoreline
Adaptation Atlas.

Timeframe: Long-Term

34.6 Subregional Shoreline Adaptation Plan
Development. In coordination with OneShoreline
and consistent with Bay Conservation and
Development Commission guidelines, prepare a
Subregional Shoreline Adaptation Plan that identifies
nature-based solutions, infrastructure
improvements, and policy strategies to address sea
level rise impacts within the same Operational
Landscape Unit as defined by the San Francisco Bay
Shoreline Adaptation Atlas.

34.7 Private Building Sea Level Rise Protection. Require new private development in areas vulnerable to sea
level rise to elevate habitable areas above projected
sea level rise elevations based on medium-high risk
scenarios through 2100, or implement alternative
flood-resistant design measures.

34.8 Existing Private Building Adaptation Assistance.

Support property owners in sea level rise vulnerable
areas by facilitating access to technical and financial assistance programs for retrofitting existing buildings with flood-resistant measures, prioritizing lowincome households and communities of concern.

34.9 Equitable Sea Level Rise Adaptation. Prioritize sea level rise adaptation investments and resiliency
programs in historically disadvantaged communities
and areas with high concentrations of vulnerable
populations, including renters, low-income
households, and communities of color.

34.10 Anti-Displacement Protections. Develop policies and programs to prevent displacement of residents in
medium- to high- risk sea level rise scenarios by
2100 due to sea level rise impacts, including tenant
protections, enforcement of relocation assistance
requirements, and affordable housing preservation
in safer areas.

IM 34.10a: Enforce the City’s tenant protection
ordinance preventing no-fault evictions in areas
subject to sea level rise adaptation projects.

Timeframe: Short-Term (Ongoing)
IM 34.10b: Provide rental assistance for residents
displaced by sea level rise impacts or adaptation
measures.

Timeframe: Medium-Term
Emergent Groundwater
Emergent groundwater is a consequence of sea level rise.

As ocean levels rise, denser saltwater moves inland
beneath the ground, pushing up the layer of less dense
freshwater that floats above it. When this freshwater is forced upward to the ground surface, it creates flooding from below—even in areas that appear protected from
coastal flooding.
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How It Affects East Palo Alto
Emergent groundwater poses unique challenges because it:
• Floods basements and underground infrastructure
from below.
• Infiltrates storm drains, reducing their capacity during rain events.
• Destabilizes building foundations and underground
pipes.
• Corrodes infrastructure not designed for saline water exposure.
• Spreads soil and groundwater contamination.
• Increases liquefaction risk during earthquakes.

As shown in Figure 10-9 and Figure 10-10, emergent
groundwater is projected to impact the majority of East Palo Alto under a high sea level rise scenario by 2050, with even further encroachment occurring by 2100. This
includes all schools, community facilities, pump stations, and parks throughout the city. Groundwater is expected to rise at the same rate as sea levels. Though these maps
show emergent groundwater areas factoring in sea level
rise inundation, it is important to note that even if levees and shoreline barriers successfully protect against direct coastal flooding, emergent groundwater would still rise beneath the ground throughout most of the city.

Contamination Concerns
Of particular concern are the dozens of sites with current or past contamination shown on Figure 10-9 and Figure
10-10. Many of these contaminated sites are in residential neighborhoods. As groundwater rises, it can seep into
these toxic sites from below, spreading hazardous
materials and pollutants far beyond the original
contamination boundaries. This spread of hazardous
materials and the increased risk of exposure to them could directly impact public health, especially in environmental justice communities. This is discussed further in the
Hazardous Materials section.

Past and Current Conditions
While emergent groundwater has not yet caused
widespread surface flooding in East Palo Alto, the city’s naturally high water table means that many areas are
already experiencing early impacts. Basements in low-lying areas occasionally experience water intrusion during wet winters, and some underground utilities show signs of
corrosion from increasingly saline groundwater.

Future Projections
Groundwater emergence will worsen progressively with
sea level rise:
• Areas with groundwater currently three to six feet
below the surface are expected to begin experiencing
groundwater emergence by 2050.
• By 2100, groundwater could emerge at the surface
across most of the city during wet seasons.
• Storm drainage systems will lose capacity as
groundwater infiltrates pipes.
• The interaction between emergent groundwater and
stormwater will cause more severe inland flooding.

Unlike coastal flooding that can potentially be addressed with levees or seawalls, emergent groundwater cannot be easily blocked. It requires comprehensive solutions
including improved drainage, building retrofits, and careful management of contaminated sites to protect public
health and safety.
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Goal SN-45. Safeguard residents and
infrastructure from emergent
groundwater hazards while preventing
contamination mobilization in vulnerable
communities.

Intent: To address the unique challenges posed by rising groundwater levels, including structural damage,
infrastructure failure, and the mobilization of soil and groundwater contamination, with particular attention to environmental justice communities.

Policies:

45.1 Emergent Groundwater in Capital Planning.

IntegrateConsider the risk of emergent groundwater
from sea level rise in the planning of Capital
Improvement Projects.

45.2 Development Requirements in Emergent
Groundwater Areas. Encourage construction and
substantial improvements in areas at risk of
emergent groundwater to conduct geotechnical
investigations that assess vulnerability to shallow
groundwater rise and incorporate project measures
to monitor and reduce impacts from buoyancy,
seepage, infiltration, liquefaction, corrosion, and
contaminant mobilization hazards.

45.34 Regional Groundwater Rise Planning. Coordinate
with OneShoreline and adjacent jurisdictions to
establish detailed understanding of shallow
groundwater rise effects on people, ecological
assets, and the built environment. Incorporate
regionally coordinated adaptation strategies for
emergent groundwater into the City’s General Plan,
Capital Improvement Plan, and Municipal Code.

45.45 Geotechnical Assessment and Mitigation for
Emergent Groundwater Areas. Encourage new
development or redevelopment in emergent
groundwater areas, as identified on Figure 10-9 and
Figure 10-10, to assess the vulnerability to shallow
groundwater rise through a geotechnical
investigation and incorporate project measures to
monitor and reduce seasonal and permanent
impacts, including buoyancy, seepage, infiltration,
liquefaction, corrosion, and contaminant
mobilization hazards.

45.5 Contaminated Site Cleanup in Emergent
Groundwater Areas. Proactively coordinate with the
San Mateo County Certified Unified Program Agency
(CUPA), California Department of Toxic Substances
Control, State Water Resources Control Board, the
State Environmental Protection Agency, and local
community-based organizations to prioritize the
cleanup and remediation of contaminated sites
located in areas vulnerable to emergent
groundwater, as shown on Figure 10-9 and Figure
10-10, where rising groundwater threatens to
mobilize contaminants, with particular emphasis on
protecting environmental justice communities and
residential neighborhoods. Encourage contaminated
sites to be fully cleaned rather than subject to
ongoing exposure management.

IM 5.5a: Continue to comply with State requirements
for vapor intrusion screening for sensitive uses on or
adjacent to contaminated sites in emergent
groundwater areas.

Timeframe: Short-Term (Ongoing)
Fire/Wildfire Hazards
While East Palo Alto does not have designated wildfire
hazard severity zones, the community faces risks from
structural fires, as exemplified by the 1997 structural fire that resulted in 9 deaths. These fires can destroy buildings and infrastructure and endanger human lives due to faulty wiring, mechanical equipment failures, or combustible
construction materials. Older buildings that lack modern fire safety features, including many of the city’s soft-story multifamily buildings, face greater risk of damage from fires. Higher-density residential structures and industrial structures – both of which figure prominently in East Palo Alto – are at elevated fire risk.

In addition to the risk posed by structural fires, the State Fire Marshal has identified portions of the bay shoreline (outside city limits and populated areas) as having an
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elevated risk from grass fires. Local fire agencies have had a long-standing weed abatement program intended to
minimize such risks. East Palo Alto may also be affected by fires elsewhere in the region, which may not directly
threaten the community but could affect regional
infrastructure used by community members, such as
transportation networks and water systems.

Fire Protection Services
The Menlo Park Fire Protection District (MPFPD) provides a variety of life safety related services to the entirety of East Palo Alto. These services include fire prevention,
inspection, and investigation, as well as firefighting, hazardous materials response, search-and-rescue, and
paramedic services. MPFPD serves a 33 square mile service area comprising the cities of East Palo Alto, Menlo Park, Atherton, and portions of unincorporated San Mateo
County. MPFPD operates a station (Station 2) within East Palo Alto at 2290 University Avenue. Station 2 staff
responds to approximately 2,000 incidents annually,
comprising about one-quarter of all of MPFPD’s annual
emergency responses. More than half of annual calls are medical emergencies.

Each of MPFPD’s seven stations provides at least one heavy fire engine and is continuously staffed by at least three crew members.

MPFPD reconstructed Station 2 starting in 2012 as an
essential service building, meaning that it is being
reconstructed to be able to withstand and continue to
operate throughout any type of major emergency.

The predominant fire-related concern in East Palo Alto is structural fire. MPFPD notes that higher density
occupancies and industrial structures – both of which
figure prominently within East Palo Alto – are at elevated fire risk. In particular, industrial structures are at
heightened risk due to the fact that many industries handle hazardous materials and fuels which, if mishandled, can result in unwanted releases.

Most people assume wildfire risks only apply in heavily forested areas. Indeed, data compiled by the State Fire Marshal indicates that most of the County’s large wildfires have occurred in hilly, forested areas well to the west and north of East Palo Alto. However, though the city itself is not designated as a high fire hazard severity zone, the State Fire Marshal has identified portions of the Bay
shoreline (outside city limits and populated areas) as
having an elevated risk from grass fires. MPFPD has had a long-standing weed abatement program intended to
minimize such risks.

While MPFPD is able to meet its response and service
goals, ongoing and increasing traffic in the service area pose operational challenges, particularly along University Avenue in East Palo Alto and other nearby major routes
like Willow Road and Marsh Road. In many circumstances, emergency responders must drive against the flow of
traffic. The Belle Haven and east sides of East Palo Alto can be more challenging to access when traffic is congested.

Wildfire Smoke Impacts
While East Palo Alto is unlikely to experience major
wildfires within its boundaries, the city is highly vulnerable to smoke from wildfires occurring throughout the region and state. Wildfire smoke contains complex mixtures of
gases and fine particulate matter (PM2.5) that penetrate deep into lung tissue and impact cardiovascular health.

Limited air monitoring resources in the city have
historically made it difficult to determine the scale of impacts and provide timely and accurate warnings to
residents.

The health risks from wildfire smoke are particularly severe for vulnerable populations, including:
• Children and older adults
• Individuals with pre-existing respiratory conditions like asthma
• People with cardiovascular conditions
• Low-income residents who may lack access to air
filtration or cannot afford to stay indoors.

Past Events
While San Mateo County has experienced fires before, few of its fires have caused sufficient damage to trigger a State or federal disaster declaration. East Palo Alto has been affected by smoke from wildfires throughout the state and region.
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The most significant recent impact was during the 2020
CZU Lightning Complex fires, which triggered 25
consecutive days of air quality alerts from the Bay Area Air District. During this period, East Palo Alto residents
experienced hazardous air quality conditions that limited outdoor activities, exacerbated respiratory conditions, and disproportionately impacted vulnerable populations who
could not access clean air facilities.

Future Conditions
Climate change is expected to increase both the frequency and severity of wildfires throughout California, leading to more frequent and prolonged periods of poor air quality from smoke. Warmer temperatures and altered
precipitation patterns will extend the fire season yearround and create conditions for larger, more intense fires.

For East Palo Alto, this means:
• More frequent "Spare the Air" days restricting
activities.
• Increased health impacts, particularly for
environmental justice communities.
• Greater need for clean air facilities and home filtration systems.
• Economic impacts from reduced outdoor work and
recreation opportunities.

The combination of existing local air pollution sources and increasing wildfire smoke creates cumulative impacts that threaten public health and quality of life, requiring
comprehensive strategies to protect residents from poor air quality.

Goal SN-563. Reduce the risk of fire and
wildfire hazards in the community.

Intent: To lessen the impacts of fire on City residents by decreasing likelihood of fire and improving response time.

Policies:

56.1 Response times. Continue to support Menlo Park
Fire Protection District (MPFPD) in helping maintain
adequate established emergency response times.

Work with MPFPD to identify choke points to help
ensure continuation of adequate consistent
emergency response in all of East Palo Alto.

56.2 Fuel reduction strategies. Continue to coordinate
with the Mid-Peninsula Regional Open Space
District, Caltrans, the Cities of Menlo Park, and Palo
Alto, and other bayfront property owners to
consider implementing fuel reduction/weed
abatement in areas of highest risk.

56.3 Location ofFire- resilient critical services and
facilities. Continue to avoid placing, essential
services and critical facilities in areas of elevated risk of wildfire. If critical facilities cannot be located
outside of risk zones, eEnsure that facilities are
constructed to appropriate standards to maintain
operations during and after disaster events.

56.4 Fire Safe San Mateo County. Continue to support
Menlo Park Fire Protection District’s participation in
the Fire Safe San Mateo County program.

56.5 Fire Service Capabilities. Support the Menlo Park
Fire Protection District in maintaining and enhancing
fire service capabilities through proactive
maintenance of fire equipment and training fire
personnel.

56.6 Fire Safe Education. Support fire prevention and
implement public education, early detection
programs, and property inspections to identify and
avoid fire hazards. Educate property owners and
residents about fire safety risks associated with
outdated electrical systems and provide information
about upgrading wiring to meet current safety
standards, ensuring public education is provided
regularly and in multiple languages and formats to
reach all residents.

IM 65.6a: Collaborate with local and regional fire
safe councils, CAL FIRE Santa Clara Unit, and other
fire protection agencies to develop a fire safe
education program to provide information about
State fuel modification, defensible space, access,
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water, signage, and other fire safe regulations.

Timeframe: Medium-Term
563.7 Emergency Services Training. Support programs for ongoing staff training focused on understanding risks
posed by older structures and infrastructure, as well
as risk-reduction activities.
563.8 Reliable Water Supply. Maintain and enhance water supply infrastructure to ensure sufficient and reliable supplies for existing and future daily demands and
firefighting suppression requirements.

Air Quality and Public Health
Air quality is a significant concern for East Palo Alto, with asthma-related emergency visit rates for children almost twice the average of the rest of the County. Poor air quality poses significant health risks, including respiratory and cardiovascular illness, with East Palo Alto’'s frontline populations experiencing some of the highest air pollution levels in San Mateo County. The health risks associated with wildfire smoke are particularly severe for frontline populations, including children, older adults, individuals with pre-existing respiratory or cardiovascular conditions, and low-resourced residents, who may experience more
severe acute and chronic health effects.

Air pollutants in East Palo Alto come from multiple sources, including mobile sources such as cars and trucks,
stationary sources like factories and other industrial sites, dust from construction sites, smoke from wildfires, and other regional sources. The financial burden of poor air quality in the Bay Area is estimated at $32 billion annually, which includes costs associated with premature deaths,
healthcare expenses, reduced productivity, and other
related issues.

Human Health Hazards and Vector-Borne Disease
Human health hazards, including bacteria, viruses,
parasites, and other pathogens, pose significant concerns in East Palo Alto. These conditions can result in physical injuries, fatalities, and mental health issues, and they exacerbate pre-existing conditions like asthma and
allergies. Rats, mice, ticks, and mosquitoes are common vectors that often spread the pathogens that can cause
illness. Mosquitoes may breed in standing water in gardens and yards, storm drains and underground pipes, and even in saltwater marshes. Mosquitoes can spread diseases
through their bites, including West Nile virus. Ticks can also spread diseases through their bites. According to testing conducted by the San Mateo County Mosquito and Vector
Control District, approximately 1 to 3 percent of San Mateo ticks carry the agent for Lyme disease.

Healthcare Access and Vulnerable Populations
East Palo Alto has limited healthcare providers, which can limit access to healthcare and exacerbate disparities in healthcare quality and access. According to the US Census Bureau and San Mateo County Health, almost 10 percent
of people in East Palo Alto live with a disability, compared to approximately 7 percent in the total of San Mateo
County. Nearly 17 percent East Palo Alto’s population has asthma and 11 percent have diabetes, while those
numbers are 15 percent and 10 percent, respectively, in San Mateo County. During community-wide health
emergencies, the demand for health services can rise
significantly, often surpassing the available staff and resources. Many residents already face systemic barriers to healthcare, such as limited medical facilities in the city and challenges related to affordability and transportation to these facilities. When hazards like extreme heat or
infectious disease outbreaks push these resources beyond capacity, marginalized communities are disproportionately affected. Persons with chronic illnesses or disabilities experience increased sensitivity to the health effects of heat and poor air quality. They may also face barriers such as limited mobility, dependence on assistive equipment or caregivers, inaccessible communication methods, and a
lack of transportation or medically appropriate shelters— making it more difficult to receive emergency alerts,
evacuate safely, or access support resources.

Past Health Events and Regional Response
San Mateo County, like the rest of the United States, was included in the March 2020 FEMA major disaster
declaration for the COVID-19 coronavirus pandemic. As of winter 2023, the county has reported a total of 184,001 COVID-19 cases and 912 deaths since monitoring began in January 2020. As recently as 2019, a major mosquito
problem was reported by approximately 50 East Palo Alto residents and may have affected significantly more
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borne disease of concern in the area, San Mateo County
has rarely had West Nile virus cases in the past two
decades, and those that have occurred were acquired
outside of the county. San Mateo County Health received confirmation in April 2016 that the first San Mateo County resident tested positive for Zika virus, with 13 cases
reported in the county in 2016.

The Bay Area Air District has played a key role in
monitoring and improving air quality throughout the
region, resulting in notable progress even as population, traffic, and industrial activities have grown. The Air District operates several programs to reduce air pollution,
including the Spare the Air Program, which issues alerts on days when air quality is expected to be poor due to high levels of ozone or particulate matter. On Spare the Air days, residents are encouraged to limit activities that contribute to air pollution, such as driving, using gas-powered
equipment, or wood burning. Employers with 50 or more
full-time employees in the Bay Area are required to
provide Commuter Benefits Programs to encourage the
use of alternative modes of transportation.

Regional Health Management and Response
San Mateo County Health provides health services,
including vaccination clinics, disease testing, and
emergency response support, to residents throughout the county. The San Mateo County Mosquito and Vector
Control District operates as the county’s community-based mosquito control program, using surveillance, prevention, and control methods to help control the risk of disease.

Contact tracing is used as a public health practice to
identify and notify people who have been exposed to
someone with an infectious disease, particularly important during pandemic events. The Health Alert Network serves as the Centers for Disease Control and Prevention’s (CDC’s) primary method of sharing urgent public health
information with public health practitioners, clinicians, and laboratories throughout the region.

Future Conditions
Climate change is expected to significantly affect the
frequency and severity of future poor air quality events and human health hazards in East Palo Alto. Warmer
temperatures will continue to increase ozone formation
and extend allergen seasons, while more frequent and
intense wildfires across Northern California will create repeated episodes of hazardous air quality from smoke
exposure. Rising temperatures and changing precipitation patterns will promote the proliferation of disease-carrying vectors, expanding their geographic range and increasing the transmission of vector-borne diseases. Proactive public health measures, enhanced regional coordination, and
expanded access to clean air facilities and healthcare
services will become increasingly critical to protect East Palo Alto residents from these evolving health threats.

Goal SN-67. Ensure clean air and protect
public health through regional
collaboration, equitable planning, and
sustainable development.

Intent: To protect public health and improve air quality through strategies that reduce exposure to air pollution and promote cleaner environments for all residents.

Policies:

67.1 Regional Collaboration for Air Quality
Management. Continue to collaborate with Bay Area
Air District and surrounding jurisdictions to address
regional air quality impacts, implement coordinated
response strategies, and support regional programs
that improve indoor and outdoor air quality,
including clean air filtration initiatives for vulnerable populations.

67.2 Compliance with Air District Standards for New
Development. Exceed compliance with Bay Area Air
District requirements for new development,
including health risk assessments, air filtration
systems, setback requirements, construction and
operation standards, and indoor air quality measures
that protect residents from exposure to poor air
quality.

67.3 Building Standards to Safeguard Against Poor Air
Quality. Exceed development and building standards
and site design features that protect residents from
exposure to poor air quality, including wildfire
smoke, and traffic-related pollution, with enhanced
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protection measures for residential areas near
freeways and other high-pollution corridors.

IM 67.3a: Require new buildings housing sensitive
receptors adjacent to Highway 101 and other major
roadways, consistent with Bay Area Air District
standards, to incorporate mechanical ventilation
systems with a filter with a Minimum Efficiency
Reporting Value rating of 13 (MERV 13) or higher,
capable of capturing at least 90 percent of medium
and large-size particles.

Timeframe: Short-Term
IM 67.3b: Require ventilation systems and indoor air
quality testing for new multifamily residential
developments consistent with applicable building
and health standards.

Timeframe: Short-Term

67.4 Air Quality Planning for Capital Improvement
Projects. Integrate air quality considerations into the planning of Capital Improvement Projects, with
emphasis on reducing exposure for environmental
justice communities and other vulnerable
populations.

67.5 Funding for Clean Air Facilities. Support and apply for funding for clean air facilities that provide refuge during poor air quality and extreme heat events. This
includes maintaining the existing permanent clean
air facilities, incorporating air filtration systems in new and renovated resilience centers, supporting
comparable private facilities, and prioritizing
locations accessible to transit-dependent and
vulnerable populations.

IM 67.5a: Apply for State and federal grants to
support clean air facility operations and
maintenance, including Air District Community
Health Protection Program funding.

Timeframe: Short-Term (Ongoing)
IM 67.5b: Establish partnerships with schools,
libraries, and community centers to create
additional clean air refuge locations accessible to
vulnerable populations.

Timeframe: Short-Term (Ongoing)

67.6 Expanding Access to Clean Air Filtration for
Vulnerable Communities. Expand participation in
the Air District’s Clean Air Filtration Program by
supporting and providing residential filter
installation and maintenance.

IM 67.6a: Partner with community-based
organizations for program implementation,
prioritizing environmental justice communities and
vulnerable populations.

Timeframe: Short-Term (Ongoing)

67.7 Prioritizing Air Quality Protection for Vulnerable Populations. Prioritize the protection of vulnerable
populations from adverse air quality impacts
through appropriate land use decisions and
development standards.

67.8 Promoting Low-Cost Transit on Spare the Air Days.

Coordinate with San Mateo County Transit District to
provide free or reduced-cost public transportation
during Spare the Air days to reduce vehicle
emissions.

67.9 Collaborative Planning for Vector-Borne Disease
Prevention. Engage with the San Mateo County
Mosquito and Vector Control District, as well as San
Mateo County Health to prepare for increased
episodes of vector-borne diseases in East Palo Alto
and the surrounding area.

67.10 Community Partnerships for Equitable Healthcare
Access. Work with local community-based
organizations to improve access to healthcare,
preventive services, and address health inequities
throughout the community.

IM 67.10a: Require ventilation systems and indoor
air quality testing for all multifamily residential
housing consistent with applicable building and
health standards.

Timeframe: Short-Term

67.11 Urban Greening Priority. Prioritize tree planting and urban greening initiatives in areas with high
pollution exposure and inadequate tree canopy
coverage.
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Severe Weather
Severe weather in East Palo Alto includes intense storms that bring heavy rain, high winds, and thunderstorms.

These events pose significant threats by disrupting daily life, compromising public safety, and damaging
infrastructure throughout the community. According to the East Palo Alto Vulnerability Assessment, severe weather events particularly threaten:
• Low-resourced households lacking reliable
transportation for evacuations or financial means to
leave.
• Older adults who face mobility challenges during
evacuations and power outages affecting medical
equipment.
• People with chronic illnesses who are more
susceptible to temperature fluctuations and stress.
• Residents of mobile homes due to structural
vulnerabilities of older manufactured housing.

Types of Severe Weather
The most common severe weather events affecting East
Palo Alto are heavy rain events often associated with
atmospheric rivers, windstorms, and occasional
thunderstorms. Atmospheric rivers are long, narrow bands of moisture in the atmosphere that transport water vapor from the tropics. When these systems make landfall, they can release intense precipitation causing flooding and
related hazards. While these storms provide critical water supply for California, they also create significant risks for low-lying communities like East Palo Alto.

Windstorms involving gusts exceeding 50-60 miles per hour occur throughout the year and can cause extensive
damage. High winds topple trees and power lines, damage buildings, and create hazardous conditions. During wet
winters, saturated soils make trees particularly vulnerable to uprooting, while dry conditions can lead to increased fire risk from downed power lines. Thunderstorms, while less common in the Bay Area, can produce lightning strikes, heavy rain, and damaging winds.

Past Events
East Palo Alto has experienced numerous severe weather
events that have caused significant damage and disruption.

Major events include:
• Severe winter storms in February 1998, which brought
heavy flooding that forced the evacuation of hundreds
of residents, damaged millions of dollars of property,
and closed major roads throughout the city. This event
triggered a federal disaster declaration.
• In October 2009, a severe windstorm caused
widespread damage across San Mateo County,
knocking down 47 trees and 31 sets of power lines.

Approximately 58,000 county residents lost power,
with damages reaching $13 million.
• A series of atmospheric river storms in December
2012, which caused severe flooding in East Palo Alto,
triggering a levee breach between Verbena Drive and
Daphne Way that forced evacuations and left one
home uninhabitable.
• Most recently, severe storms from December 2022
through March 2023 brought flooding along San
Francisquito Creek, damaged property and buildings,
flooded Highway 101, and caused widespread power
outages. Downed power lines forced closures of
University Avenue and Cooley Avenue.

Secondary Impacts
Severe weather creates cascading impacts beyond
immediate wind and water damage. Power outages from
downed lines can last for days, affecting vulnerable
populations who rely on electricity for medical equipment or lack resources to replace spoiled food. Storm debris blocks roads and hinders emergency response. Saturated
soils increase the risk of infrastructure damage and tree failures long after storms pass.

Public Safety Power Shutoff (PSPS) events, while not
weather events themselves, compound severe weather
impacts. Pacific Gas and Electric Company (PG&E) may
preemptively cut power during high wind conditions to
prevent wildfire ignitions, leaving residents without
electricity during critical times.
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Future Conditions
Climate change is expected to intensify severe weather
patterns affecting East Palo Alto. While annual average precipitation levels may increase only slightly, the nature of storms will change dramatically. Atmospheric rivers are projected to become more intense, delivering larger
amounts of precipitation in shorter timeframes. This
pattern of fewer but more extreme storms will increase
flood risk, overwhelm drainage systems, and create longer dry periods between events that harden soils and worsen subsequent flooding. The combination of more intense
storms and aging infrastructure poses growing challenges for community safety and resilience.

Goal SN-78. Enhance community
resilience to severe weather events
through improved infrastructure,
emergency preparedness, and
coordinated response
capabilitiesSafeguard residents and
infrastructure from emergent
groundwater hazards while preventing
contamination mobilization in vulnerable
communities.

Intent: To protect residents and property from atmospheric rivers, windstorms, and other severe weather events that can cause flooding, power outages, and infrastructure
damage, while ensuring vulnerable populations receive
timely support during and after eventsaddress the unique challenges posed by rising groundwater levels, including structural damage, infrastructure failure, and the
mobilization of soil and groundwater contamination, with particular attention to environmental justice communities.

Policies:

T78.1 Severe Weather Infrastructure Resilience.

Implement proactive infrastructure hardening
measures to withstand atmospheric rivers,
windstorms, and severe precipitation events,
including upgrades to stormwater systems,
strengthening of critical utility infrastructure, and
installation of backup power systems at essential
facilities to maintain operations during extended
outages.

78.2 Severe Weather Early Warning and Response.

Enhance community alert systems specifically for
severe weather events, including atmospheric rivers
and windstorms, with multilingual and multi-format
communications that provide actionable guidance
for residents. Coordinate with Pacific Gas and
Electric Company regarding Public Safety Power
Shutoff events to ensure vulnerable populations
receive advance notice and resource support.

78.3 Post-Storm Recovery and Debris Management.

Establish rapid response protocols for post-storm
recovery that prioritize clearing of evacuation routes
and restoration of services to critical facilities.

Develop pre-positioned contracts for debris removal
and infrastructure repair to reduce recovery time,
particularly in areas serving vulnerable populations
identified in the vulnerability assessment.

78.4 Private Property Severe Weather Resilience.

Support property owners in implementing severe
weather protection measures for homes and
businesses, with priority assistance for vulnerable
populations and essential local businesses.

IM 78.4a: Develop design guidelines for residential
severe weather protection as part of emergency
preparedness, including roof tie-downs, storm
shutters, and landscaping practices to minimize wind
damage.

Timeframe: Medium-Term
IM 78.4b: Partner with local non-profits to explore
assisting property owners with tree management,
such as free or low-cost tree trimming and removal
services for hazardous trees on private property that
threaten public safety, where feasible.

Timeframe: Medium-Term

78.5 Utility Resilience and Backup Power Support. Work
with the Pacific Gas and Electric Company to
enhance community resilience to power outages
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through improved utility coordination and expanded
access to backup power systems.

IM 78.5a: Develop and implement proactive
protocols for Public Safety Power Shutoff (PSPS)
events, including advance community notification
and outreach in multiple languages, prepositioning
of backup batteries and mobile power units at
critical facilities and resilience centers, deployment
of temporary cooling and charging stations, and
coordination with vulnerable populations to ensure
access to medical equipment and life-sustaining
resources during planned outages.

Timeframe: Short-Term
Extreme Heat
Extreme heat threatens public health, infrastructure, and the environment in East Palo Alto. Extreme heat days are when temperatures exceed 98 percent of historical highs for the area, as measured between April and October from 1961 to 1990. In East Palo Alto, an extreme heat day is one where the maximum temperature is above 92.4 degrees
Fahrenheit. Extended periods of extreme heat, known as
heat waves, threaten community health and increase
energy costs. When daily minimum temperatures remain
significantly above normal, warm nights can worsen an
extreme heat day because overnight temperatures do not
provide the community with relief from high temperatures.

A warm night in East Palo Alto is when temperatures
remain above 60.9 degrees Fahrenheit.

Extreme heat is one of the deadliest climate-related
hazards nationwide, with the Center for Disease Control and Prevention noting a rise in heat-related deaths from 297 in 2004 to over 2,300 in 2023. Extreme heat can be
particularly dangerous in places like East Palo Alto, where a typically mild climate means that community members are unaccustomed to very high temperatures and may be less
able to adapt. Even slight increases in temperature can overwhelm the ability of community members to cope
with extreme heat and warm nights, straining public health systems and infrastructure. This leads to heightened risks of dehydration, heat-related illnesses, and respiratory issues, disrupting daily life and economic activity. Extreme heat also stresses infrastructure, as heightened air
conditioning demand risks overloading the power grid and causing outages, and very high heat can degrade
transportation systems leading to delays and damage.

Extreme heat poses particularly severe risks for vulnerable populations, including:
• Older adults with chronic health conditions like heart disease, diabetes, and respiratory issues.
• Low-resourced households who may lack air
conditioning or cannot afford higher energy costs.
• People with disabilities who depend on electricity for medical devices or medication storage.
• Residents of mobile homes lacking adequate
ventilation systems.
• Outdoor workers in landscaping, construction, and
other industries.

Figure 10-11 shows the areas of East Palo Alto that may experience higher temperatures on extreme heat days due to limited shade cover and presence of heat-absorbing
materials. Areas most at risk include the neighborhood
surrounding Cesar Chavez Ravenswood Middle School, the
Gateway 101 Shopping Mall, and the
commercial/industrial center along Bay Road towards
Cooley Landing. Warmer temperatures and the urban heat
island effect can exacerbate extreme heat impacts in
densely populated areas, especially those that have limited tree canopy.

Past Events
CalHeatScore: A Local Heat-Risk Tool
CalHeatScore is California’s new statewide tool for
identifying and communicating heat-health risks at the
ZIP-code level. Developed by CalEPA and partners, the
system uses a 0–4 scale to rate daily heat risk based on forecasted temperatures, historical health data, and
community vulnerability. A score of 4 indicates severe
health risk—more than double the typical rate of heatrelated illness. This tool helps residents, local governments, and emergency planners better
understand, prepare for, and respond to extreme heat
events. Visit calheatscore.calepa.ca.gov for real-time
local scores and safety resources.
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Historically, East Palo Alto has experienced an average of five extreme heat days per year, with extreme heat days being most frequent in September in recent years. The city has recorded several notable extreme heat events that
have impacted the community:
• July 22, 2006: High temperatures reached 103 degrees
Fahrenheit with nighttime lows only falling into the
lower 70s.
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Figure 10-11: Heat Severity Index
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• September 1, 2017: A strong upper-level ridge brought widespread hot temperatures, breaking numerous
daily and monthly records, with three San Mateo
County residents dying from heat-related causes.
• June 10, 2019: An early season heat wave triggered
power outages affecting 57,000 people across nine
counties, including San Mateo County, over two days.
• August 19, 2020: A prolonged heat wave lasting
almost a week brought widespread record-breaking
temperatures with multiple days of triple-digit
afternoon highs.
• September 6, 2022: A strong ridge of high pressure led to anomalously hot temperatures, shattering several
daily, monthly, and all-time temperature records, with
reports of power outages, heat-related illnesses, and
deaths.

Future Conditions
Climate change is expected to significantly increase the frequency and intensity of extreme heat events in East Palo Alto. Extreme heat days are expected to increase from a historic annual average of 5 days per year to an average of 14 days per year by mid-century (2035-2064) and 25 days per year by late century (2070-2099). Warm nights are
projected to increase dramatically from a historic 5 nights per year to 39 nights per year by mid-century and 100
nights per year by late century. These projections indicate that extreme heat will become a much more frequent and
persistent threat to the East Palo Alto community, with warm nights preventing nighttime recovery from daytime
heat exposure.

Goal SN-89. Enhance community
resilience to extreme heat.

Intent: To lessen the impacts of extreme heat on City
residents and property.

Policies:

89.1 Drought-Tolerant Green Infrastructure. Promote the use of drought-tolerant green infrastructure,
including landscaped areas, as part of cooling
strategies in public and private spaces. Prioritize
installation of green infrastructure and trees in areas most vulnerable to heat.

IM 89.1a: Implement and maintain green
infrastructure requirements for all feasible public
and private projects in accordance with the City’s
Green Infrastructure Plan, emphasizing the use of
drought-tolerant vegetation, low-impact
development practices, and design strategies that
enhance cooling, stormwater management, and
climate resilience.

Timeframe: Short-Term

89.2 Urban Tree Canopy. Expand the urban tree canopy
to reduce extreme heat impacts and support carbon
sequestration, while proactively managing and
maintaining the urban forest to increase tree
resilience and reduce the risk of downed trees
during severe weather.

89.3 Urban Tree Planting. Expand urban tree-planting
programs in areas with high pedestrian activity and
in neighborhoods with low tree canopy coverage and
high exposure to urban heat island effects. Ensure
community participation in the selection of tree
species and planting locations to address local
needs.

89.4 Installation of Shade Structures and Trees. Install shade structures and trees, both green and built
infrastructure, at parks, schools, along public streets, walkways, and trails, and at other public spaces to
reduce ground surface temperatures.

Urban Heat Island Effect
The Urban Heat Island Effect occurs when urban areas
experience significantly warmer temperatures than
surrounding rural areas. This happens because
concrete, asphalt, and buildings absorb and retain heat more than natural landscapes. Urban areas can be 2-
5°F warmer during the day and up to 22°F warmer at
night compared to nearby rural areas. Areas with
limited tree cover and green space experience the
most intense heat island effects.
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IM 89.4a: Coordinate with SamTrans to install shade
structures at all City bus stops within areas scoring
"Moderate" to "Severe" on Heat Severity Index by
2028.

Timeframe: Medium-Term

89.5 Sustainable, Energy-Efficient, and Environmentally Regenerative Features. Encourage new
developments and existing property owners to
incorporate sustainable, energy-efficient, and
environmentally regenerative features into their
facilities, landscapes, and structures to reduce
energy demands and improve on-site resilience.

Include support for emergency power supplies,
including solar panels and battery energy storage
systems. Support financing efforts to increase
community access to these features.

IM 89.5a: Explore expediting the permitting process
for heat mitigation improvements including solar
energy installations, cool roofs, and energy-efficient
cooling systems.

Timeframe: Medium-Term

89.6 Sustainable Features for Rental Properties. Create incentive programs and requirements for rental
property owners to incorporate sustainable, energyefficient cooling features to protect tenants during extreme heat events. Support financing efforts to
increase property owner and tenant access to these
features.

89.7 Extreme Heat Public Outreach. Develop and
implement public outreach campaigns to educate
residents about the risks of extreme heat, effective
heat-mitigation strategies, and available resources
during heat events, as well as providing updates on
City initiatives in progress. Ensure campaigns are
multilingual, multimodal, and iterative to reach all
community members.

89.8 Shading and Heat-Mitigating Materials. Coordinate
with SamTrans to increase shading and use of heatmitigating materials at transit stops.

89.9 Rental Housing Climate Controls. Encourage
landlords to meet minimum cooling needs for rental
housing to protect tenant health during extreme
heat events, including providing functional cooling
systems.

89.10 Home Weatherization and Retrofit Programs.

Conduct focused outreach to raise awareness about
home weatherization and retrofit programs,
including available financial incentives, in lowincome neighborhoods and households with limited English proficiency.

89.11 Extreme Heat Emergency Response. Develop
comprehensive emergency response protocols for
extreme heat events to protect public health and
ensure coordinated community support consistent
with AB 2684 requirements.

IM 89.11a: Create mobile cooling unit program to
serve residents unable to access fixed cooling
centers, prioritizing households with medical
vulnerabilities.

Timeframe: Medium-Term
IM 89.11b: Collaborate with neighboring
jurisdictions on development and implementation of
a regional extreme heat response plan. The plan will
include the creation of equitably distributed and
accessible community cooling centers,
weatherization of public buildings to enhance heat
resilience, temperature thresholds for activating
cooling centers, and targeted cooling strategies to
protect outdoor workers and individuals
experiencing homelessness.

Timeframe: Short-Term
Drought
Drought is a significant decrease in water supply relative to what is needed to meet typical demand, leading to a water shortage for some activity, group, or environmental sector.

While drought is a normal occurrence for Mediterranean
climates such as that of San Mateo County, long and severe droughts have the potential to impact ecosystems and
economic activity across the entire community. Most
droughts are defined based on declines in average
precipitation levels, declines in agricultural production, 192
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declines in streamflow and groundwater levels, or
socioeconomic impacts from water shortages. The severity of any given drought depends on the degree of moisture
deficiency, the duration, and the size and location of the affected area.

Drought Hazards
While drought does not typically directly result in loss of life or damage to structures, drought can have widespread impacts on the environment and the economy. Potential
drought impacts include loss of crops, costs incurred by having to drill new wells, increased costs for water
straining household finances and reducing commercial
profits, reduced habitat and food supply for plants and animals, and increased risk of wildfire. A prolonged lack of precipitation dries out vegetation and makes plants more vulnerable to pests, both of which can increase
susceptibility to wildfires. Drought conditions especially burden:
• Low-resourced households who face water
affordability concerns and cannot afford waterefficient appliances. • Food-insecure residents who may see increased food
prices due to agricultural impacts.
• Community gardens and local food programs that
support vulnerable populations.
• Residents who are dependent on community-based
food distribution programs.
• Households already struggling with utility costs who
face additional conservation pricing.

Drought response is determined case by case, and
response priorities are typically based on imminence of potential water shortages.

In East Palo Alto, a history of regulatory decisions and limited infrastructure have constrained the City's water supply and exacerbated drought conditions. Despite the
city's low per-capita water consumption, the city's water demand exceeded its available supply several times since 2001 due to limited water allocations from the SFPUC
Regional Water System that did not keep pace with
population growth. Due to the inability of its water
allocations to support new development, the City issued a two-year moratorium on new construction in 2016 and did not allow new developments to progress unless developers could show that they had access to the necessary water.

The City ultimately pursued two strategies for expanding its water supply: seeking more water from the SFPUC
system and developing groundwater supplies, including
water transfers with neighboring jurisdictions and
expanding operations at the Gloria Well. These efforts have helped to fortify the City’s water supply; however, East Palo Alto still faces water supply and quality challenges that are being addressed through current countywide drought
resiliency planning efforts.

Past Events
San Mateo County has a history of severe droughts, with data from the early 1900s showing multi-year droughts
from 1912 to 1913, 1918 to 1920, 1922 to 1924, and 1928 to 1934. More recent prolonged droughts that have
impacted the planning area include:
• 1976 to 1977: California had a severe drought due to
lack of rainfall, with 1977 being the driest period on
record in California at that time. Over $2.6 billion in crop damage was recorded in 31 counties, and FEMA
declared a drought emergency for all California
counties.
• 1987 to 1992: California received precipitation well
below average levels for four consecutive years. By
February 1991, all 58 counties in California were
experiencing drought, with the State Water Project
sharply decreasing deliveries to water suppliers.

East Palo Alto’s Water Supply
The City of East Palo Alto purchases most of its potable water from the San Francisco Public Utilities
Commission (SFPUC) Regional Water System.

Approximately 85 percent of the water supply to the
SFPUC system originates in the Hetch Hetchy
watershed in Yosemite National Park and flows down
the Tuolumne River. The remaining 15 percent of the
water supply originates locally in the Alameda and
Peninsula watersheds. The cCity also sources a small
amount of groundwater from the San Mateo Plain
groundwater subbasin, which is part of the Santa Clara
Valley Groundwater Basin.
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• 2007 to 2009: The state proclaimed a statewide
drought emergency in June 2008 after spring 2008 was
the driest spring on record. State courts imposed what
was, at the time, the largest court-ordered water
restriction in state history.
• 2012 to 2017: This drought set several records for the state, with 2012 to 2014 ranking as the driest three
consecutive years for statewide precipitation. Calendar year 2014 set new records for statewide average
temperatures and for low water allocations from the
State Water Project.
• 2020 to 2023: The U.S. Department of Agriculture
declared a drought disaster that included San Mateo
County in April 2020. Between April and December
2021, San Mateo County was at the D3—Extreme
Drought level, putting the county at risk for wildfire on a year-round basis.

Future Conditions
Climate change is likely to result in more frequent and severe droughts across the state. Overall, precipitation levels are expected to increase slightly in East Palo Alto, from a historical annual average of 16.3 to 17.9 inches by mid-century (2035 to 2064) and 19.9 inches by latecentury (2070 to 2099). However, more years with extreme levels of precipitation, both high and low, are likely as a result of climate change. Reduced winter precipitation
levels and warmer temperatures have greatly decreased
the size of the Sierra Nevada snowpack, which in turn
makes less fresh water available for communities
throughout California. More intense droughts are expected to compact and harden soils, so when rain does return,
more water will run off as stormwater rather than infiltrate into soils, potentially causing downstream flooding while reducing groundwater recharge.

Goal SN-910. Ensure water security and
community resilience during drought
conditions through conservation,
efficiency measures, and sustainable
water management practices.

Intent: To maintain sufficient and reliable water supplies for residential, commercial, and emergency needs during
drought periods while promoting conservation practices
that reduce long-term vulnerability to water shortages.

Policies:
910.1 Drought-Tolerant Landscaping Standards. Ensure
drought-tolerant landscaping for new development
complies with state Water Efficient Landscape
Ordinance standards while ensuring landscaping
choices do not create wildfire or flooding risks.
910.2 Public Right-of-Way Rainwater Harvesting. Install rainwater catchment and bioretention systems in
public rights-of-way to support groundwater
recharge and drought resilience.
910.3 Municipal Landscape Drought Adaptation. Retrofit
City-owned landscapes, parks, and facilities with
drought-resistant and native plant species.

IM-910.3a Smart Irrigation and Alternative Water
Use. Install smart irrigation controllers in retrofitted areas and utilize recycled water, graywater, or
captured rainwater where irrigation remains
necessary.

Timeframe: Medium-Term
910.4 Community Water Stewardship Education. Provide
comprehensive multilingual education programs that
teach residents advanced water conservation
practices and drought preparedness strategies.
910.5 Alternative Water Systems Development. Promote
development and use of greywater, recycled water,
and other alternative water systems to reduce
dependence on potable water supplies.
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IM 910.5a: Update building code to streamline
permitting for residential graywater and rainwater
harvesting systems.

Timeframe: Medium-Term
Transportation Hazards
Airport Operations
Safety risks associated with airport operations comprise a distinct hazards category. Lands surrounding or near an airport have an increased risk of experiencing accidents involving aircraft.

The Palo Alto Airport is a general aviation facility located just south of East Palo Alto. The airport is owned and
operated by the City of Palo Alto, but . Santa Clara County will managed the airport until 2017, when the City of Palo Alto assumed operations following the end of a 50-year
lease. Airport and land use compatibility issues are
overseen by the Santa Clara County Airport-Land Use
Commission.

As shown in Figure 10-11512, the northern edge of the
airport’s runway is immediately adjacent to San
Francisquito Creek, which in this location serves as both City and County boundary. The County (amended in 2020)
has prepared a comprehensive land use plan (CLUP), last amended in 2020, for the Palo Alto Airport, which
identifies zones around the airport where land use and
building height restrictions are needed to guard against potential conflicts with airport operations.

California law (Government Code 65302.3) requires that a local general plan be consistent with the applicable airport land/use plan compatibility criteria in the relevant adopted airport land use plan.

The Palo Alto Airport land use plan identifies building height restrictions (pursuant to Federal Aviation
Regulations part 77) to ensure no obstructions to air
navigation are created. A portion of the height restriction zone extends into the Baylands area of East Palo Alto which is commonly known as the Faber-Laumeister Tract and is
part of the Don Edwards San Francisco Bay National
Wildlife Refuge (Refuge). The Baylands are the only portion of East Palo Alto within the Palo Alto Airport Influence Area (AIA). This General Plan maintains the refuge in open space use. The open space designation is focused on maintaining and preserving open space and other public recreational uses. The General Plan proposes no new residential or
commercial development in the Baylands area. Given the
open space designation, there would be no navigation
obstruction.

The Palo Alto Airport is one of the busiest general aviation airports in the Bay Area. Over the past decade, the airport has averaged approximately 155,000 operations (takeoffs and landings) annually. Recent projections indicate
operations may climb toward 200,000 annually within 15
years. As of 2024, approximately 353 aircraft lease space at the airport.

The City of Palo Alto launched the Long-Range Facilities and Sustainability Plan (LRFSP) in 2023 to guide airport improvements over the next 20 years, with a focus on
safety, sustainability, and resiliency. The LRFSP evaluated five alternatives for airport facilities, developed in
accordance with FAA criteria (including alternatives that would modify the airport's existing 2,443-foot runway) but identified no preferred alternative. Following substantial community opposition regarding potential environmental
and noise impacts on the Baylands and adjacent
communities, the Palo Alto City Council directed staff in September 2024 to reconsider planning alternatives
without expanding the airport's footprint. The LRFSP is on pause as of January 2026 while the City makes near-term progress on leaded fuel transition and noise reduction
effortsstarted’a runway length of .

The airport serves important community functions,
including as the main refueling location for life flight helicopters serving Stanford Medical Center and as a
destination for Angel Flight aircraft bringing patients to Palo Alto for medical care.

The frequency and severity of future airport hazards in East Palo Alto will depend on the scale of future activities. Given projections for increased operations, along with ongoing regional aviation growth, monitoring and coordination with airport operators and regional planning agencies will
remain important for managing potential impacts on East Palo Alto.
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Figure 10-12: Airport Safety Zones and Hazardous Sites
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Surface Transportation/Pedestrian
Surface transportation, such as cars and trucks, also poses risks to the safety and well-being of people. According to data compiled by the California Office of Traffic Safety, East Palo Alto ranked third out of 97 California cities surveyed for the number of pedestrian collisions per daily vehicle miles traveled. A 2007 study showed that the Ccity
experienced 74 fatal or injury causing traffic collisions. Of these incidents, 13 involved pedestrians and 17 were of a “hit and run” naturehas historically experienced high rates of vehicle collisions with pedestrians and bicyclists,
particularly among major arterials such as University
Avenue and at key intersections.

Between 2018 and 2022, East Palo Alto reported 458 fatal and injury crashes on surface streets (at-grade roadways), including 48 fatal/severe injury crashes. Pedestrians were involved in 27 percent of fatal/severe injury crashes and 12 percent of all crashes. Bicyclists were involved in 21
percent of fatal/severe injury crashes and 16 percent of all crashes. The City’'s 2024 Local Roadway Safety Plan
identifies University Avenue as a high-priority corridor, with multiple intersections along University Avenue
ranking among the top locations for safety improvements due to documented collision patterns.

The City has made significant improvements in recent
years. The 2025 University Avenue Safety Enhancements
Project has a goal of reducing collisions at four highpriority intersections along University Avenue, identified through a community-wide safety analysis. The project
includes improved pedestrian crossings, upgraded signal equipment for visibility, and protected left-turn phases to separate conflicting vehicle movements. In 2025, the City also opened a pedestrian overcrossing at University
Avenue and Highway 101, addressing a documented
hazard area where 26 bicycle collisions occurred within one block between January 2024 and June 2025.

While these improvements are expected to reduce
collisions, pedestrian and bicycle safety remains a priority concern. This is particularly true given that East Palo Alto is a major commuter corridor due to its proximity to Highway 84 (Dumbarton Bridge) and the concentration of
residential neighborhoods near major arterials.

Goal SN-1014. Protect the community
from public safety hazards related to
aircraft and surface transportation, and
hazardous materials.

Intent: To help City residents avoid human-made hazards and maintain lives of maximum security and freedom from harm.

Policies:

4.1 Contamination. Avoid or minimize risk to the
community from exposure to contaminated soils or
groundwater.

4.2 Management of hazardous materials. Continue to
cooperate with federal, state, and county agencies to
effectively regulate the management of hazardous
materials and hazardous waste.

4.3 Risk Management Plans. Continue to cooperate with
the Certified Unified Program Agency (CUPA) for East
Palo Alto (the County of San Mateo Health System)
and the Menlo Park Fire Protection District to
administer Risk Management Plans for businesses
within the City.
1014.14 Transportation safety. Minimize transportation
accidents by considering pedestrian safety in all land
use planning decisions and working closely with CHP,
Caltrans, SamTrans, and other relevant agencies to
identify safety problems and implement corrective
measures.

IM 11.1a: Prioritize implementation ofImplement
safety improvements identified in the 2024 Local
Roadway Safety Plan and coordinate with regional
partners, including the City/County Association of
Governments of San Mateo County (C/CAG) and the
San Mateo County Transportation Authority, to
pursue Highway Safety Improvement Program (HSIP)
funding and other safety grant opportunities.

Timeframe: Short-Term/Ongoing
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1014.25 Airport land use plan. Coordinate with the Santa Clara County Airport Land Use Commission and Palo
Alto Airport Comprehensive Land Use Plan (CLUP)
and consider the CLUP in making any land use
decisions in the airport influence area. 4.6 Gas
pipeline emergency prevention and planning. The
City shall coordinate with the Menlo Park Fire
Protection District, and other local, regional, and
state agencies to ensure that emergency evacuation
plans are in place and any major pipelines in the
community are appropriately inspected and marked
to prevent accidental rupture.
101.3 Traffic Safety Infrastructure Maintenance. Maintain and enhance traffic control infrastructure, including
traffic signals, crosswalks, speed control measures,
and pedestrian safety features to ensure both daily
safety and emergency response capability.

Implement proactive maintenance programs to
prevent traffic signal outages and address
infrastructure failures that compromise pedestrian
and vehicle safety.

Hazardous Materials
Hazardous materials are materials that pose a significant risk to public safety or human or environmental health, including toxic chemicals, flammable or corrosive
materials, petroleum products, and unstable or
dangerously reactive materials. They can be released
through human error, malfunctioning or broken
equipment, or as an indirect consequence of other
emergencies such as earthquakes, floods, or severe
weather. Hazardous materials can also be released
accidentally during transportation as a consequence of
vehicle accidents. A release or spill could result in fire, explosion, toxic cloud, or direct contamination of water, people, and property, with effects potentially involving a local site or many square miles.

As cities age and patterns of development change, former industrial properties, gasoline stations, and other parcels with land uses associated with hazardous materials (which can include agricultural uses) are often abandoned. These properties, where soils and groundwater are known or
suspected to be contaminated, are often referred to as
“brownfields”. The threat of contamination and potential liability for cleanup costs drives developers away from brownfields and encourages growth on previously
undeveloped parcels at the outskirts of urban areas. This results in the inefficient use of land, blight in older portions of cities and, most importantly, the potential for adverse health impacts on nearby residents.

Several different types of hazardous material
contamination have been documented in East Palo Alto in numerous previous studies (including but not limited to the Ravenswood Business District/4Corners (RBD)TOD
Specific Plan EIR, the Facebook EIR, and the 1999 2016
General Plan EIR), as shown in Figure 10-59 and Figure 10-

10. The greatest concentration of affected sites is in the Ravenswood TOD Specific Plan Area, centered around Bay
Road and the Cooley Landing area. This area was
historically home to numerous industrial uses dating back to the 19th century. The handling, use, and disposal of hazardous materials were not as tightly regulated as they are today; consequently, many historic industrial sites are marked with moderate to substantial contamination of
soils and groundwater.

PCBs, metals, petrochemicals, and other harmful materials can be found at such sites. Many of these sites are
currently undergoing clean-up activities, and others have restrictions that prohibit sensitive uses like homes or schools to be being placed on top.

General aviation aircraft have historically used leaded aviation gasoline (100LL - 100 octane low lead), which
contains tetraethyl lead as an octane booster. Palo Alto Airport is transitioning to unleaded aviation fuel to
eliminate lead emissions. In December 2024, the aAirport introduced Swift 100R, a high-octane unleaded aviation
fuel that can be used as a drop-in replacement for 100LL in most piston-engine aircraft. The transition to unleaded fuel will eliminate a source of lead emissions that can impact air quality and public health, particularly for communities near the airport flight path.

Besides industrial sites, other documented sources of
hazardous materials in the Ccity include areas of
uncontrolled fill, former gas stations (particularly if underground storage tanks leaked), and areas formerly in agricultural use. Though agricultural uses may sound
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relatively benign when compared to industrial uses or gas stations, former agricultural properties will often have pesticide residue in the top two feet or more of soil. In addition, buildings constructed and/or painted before the late 1970s may contain asbestos and/or lead-based paint; demolition or removal of such buildings must conform to federal and state policies to ensure the safe handling and disposal of hazardous materials.

As a result of a cluster of agricultural, heavy
manufacturing, chemical manufacturing and auto wrecking uses, the City of East Palo Alto was nominated a
Brownfields Showcase Community in 1997. The Gateway
101 and University Circle area brownfields were
redeveloped, and now contribute significant revenue to
the City’s general fund. The adoption of the Ravenswood TOD Specific Plan is the first major step to remediate the City’s remaining brownfields, which are clustered in the Ravenswood Employment District.

Current hazardous materials management is overseen by
multiple agencies working in coordination, such as the
Environmental Protection Agency, State Regional Water
Quality Board, and the Department of Toxic Substances
Control. San Mateo County Environmental Health Services serves as the Certified Unified Program Agency (CUPA) for the county, managing hazardous materials and waste
regulation including Hazardous Materials Management,
California Accidental Release Prevention, Hazardous Waste Management, Underground Storage Tanks, Aboveground
Storage Tanks, and Emergency Response programs. The
Menlo Park Fire Protection District issues operational
permits for the storage and use of hazardous materials and works with the CUPA to coordinate proper handling and
enforcement.

Past Events
Hazardous materials incidents have occurred periodically in East Palo Alto and the surrounding region. Eighteen
hazardous materials incidents have been reported in East Palo Alto since 2006, with fifteen of these incidents related to petroleum exposure and three classified as chemical
incidents. While these local incidents were relatively minor, the 2010 San Bruno natural gas pipeline rupture
demonstrates the potential for more severe regional
impacts, where eight people lost their lives, 51 required hospitalization, 38 homes were destroyed, and property
damage exceeded $220 million.

Future Conditions
The frequency and severity of future hazardous materials releases in East Palo Alto will depend on the scale of future activities but increases in the frequency and severity of other natural hazards, such as floods, can affect the
frequency and severity of future hazardous materials
releases. Climate change impacts such as sea level rise and emergent groundwater pose particular concerns for
contaminated sites in East Palo Alto, as rising groundwater levels could mobilize existing soil and groundwater
contamination, potentially spreading pollutants to
previously uncontaminated areas and complicating
ongoing remediation efforts.

Goal SN-112. Protect community health
and safety from hazardous materials
exposure through responsible
management, remediation of
contaminated sites, and prevention of
new contamination.

Intent: To help City residents avoid human-made hazards and maintain lives of maximum security and freedom from harm
Policies:
112.1 Contamination. Avoid or minimize risk to the
community from exposure to contaminated soils or
groundwater.

IM 112.1a: Coordinate with San Mateo County
Environmental Health Services (CUPA) to maintain an
updated database of all known and suspected
contaminated sites. Ensure sharing of this database
with community members and hold public,
multilingual workshops to understand the
information therein.

Timeframe: Short-Term (Ongoing)
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112.2 Management of hazardous materials. Continue to
cooperate with federal, state, and county agencies to
effectively regulate the management of hazardous
materials and hazardous waste.
112.3 Risk Management Plans. Continue to cooperate with the Certified Unified Program Agency (CUPA) for East
Palo Alto (the County of San Mateo Health System)
and the Menlo Park Fire Protection District to
administer Risk Management Plans for businesses
within the city.
112.4 Safe Siting and Design for Hazardous Material
Facilities. Protect public health through appropriate
siting and design requirements for facilities that use, manufacture, or store hazardous materials.

IM 112.4a: Coordinate with Caltrans and CHP to
establish designated hazardous materials
transportation routes avoiding residential areas and
schools.

Timeframe: Short-Term
112.5 Prohibit Hazardous Facilities in Groundwater Areas.

Prohibit new facilities that use, manufacture, store,
or transport hazardous materials in emergent
groundwater areas, as shown on Figure 10-9 and
Figure 10-108.
112.6 Gas pipeline emergency prevention and planning.

Coordinate with the Menlo Park Fire Protection
District, and other local, regional, and state agencies to ensure that emergency evacuation plans are in
place and any major pipelines in the community are
appropriately inspected and marked to prevent
accidental rupture.
112.7 Mitigate Hazardous Material Risks from
Groundwater. Require existing facilities in emergent
groundwater areas that handle hazardous materials
to implement comprehensive monitoring,
containment, and emergency response measures to
prevent contamination from groundwater intrusion.

Establish requirements for relocating or
decommissioning highest-risk facilities based on
vulnerability assessments.

IM 12.7a: Require contamination investigation and
cleanup plan approval prior to the commencement
of grading or earthwork on sites in emergent
groundwater areas where hazardous materials are
known or suspected to be present.

Timeframe: Short-Term
IM 12.7b: Develop a long-term monitoring plan for
sites in emergent groundwater areas where full
remediation has not been achieved, incorporating
best available science to detect and respond to
contaminant remobilization over time, in
coordination with the San Mateo County CUPA,
DTSC, and State Water Resources Control Board.

Timeframe: Long-Term
IM 12.7c: Staff will continue to comply with all state
requirements pertaining to sewer discharge and will
update its sewer system management plan in
accordance with the requirements of the State
Water Board to ensure proper system operation.

Timeframe: Long-Term
Noise
Noise is typically defined as unwanted sound and is usually objectionable because it is disturbing or annoying.

Excessive noise may result in hearing loss, interference with normal activities such as sleep, speech
communication, work, and recreation, or annoyance,
which may impact quality of life.

The City’s noise ordinance is designed to protect people from non-transportation noises sources such as music,
construction activity, machinery and pumps, and air
conditioners. The Noise Ordinance does not apply to
railroad operation, maintenance and construction activities occurring within the Union Pacific right-of-way or the
permitted hours for such activities. The ordinance also does not apply to noise generated by aircraft activity at Palo Alto Municipal Airport.

Noise from transportation activity is the primary
component of the noise environment in East Palo Alto.
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Transportation corridors that traverse East Palo Alto, such as Highway 101; major arterial roadways, such as Willow Road, University Avenue, and Bay Road; and collector
roadways, such as Clarke Avenue and Pulgas Avenue, are
the predominant sources of environmental noise. Figure
10-1132 shows existing noise exposure generated by traffic in East Palo Alto, based on 2015 conditions. Figure 10-1243 shows estimated 2040 noise exposure generated by traffic in East Palo Alto, accounting for conditions resulting from new development proposed by this General Plan.

The most effective methods for mitigating transportation noise impacts on new noise-sensitive land uses involve
appropriate planning, such as the site design review
process and CEQA (when applicable). During these stages of the development process, potential impacts from
transportation noise will be identified and mitigation
measures will be required as needed to meet City noise
standards. Site planning, topography and the design and construction of noise barriers (walls, berms, or
combination of walls/berms) are the most common
methods of alleviating traffic and train noise impacts.

Setbacks and buffers can also be used to achieve small
noise reductions. Careful consideration should be given to proposed projects that qualify for statutory or infill
exemptions in order to avoid potential noise impacts due to transportation noise. The noise contour maps contained in the noise element should be reviewed by planning staff to ensure that the noise environment at a particular
project site is appropriate for the proposed land use.

Aircraft activity from the Palo Alto Municipal Airport forms the primary source of noise in the eastern portion of the Ccity, where roadway traffic noise sources are limited. This area is located below the flight path for the Palo Alto Municipal Airport. In addition to local airplane activity, overflight from jet aircraft is another source of noise associated with aircraft, particularly from aircraft arriving at San Francisco International Airport. Aircraft noise
primarily affects people who live, work, or play in the vicinity of the airport. Bayfront areas are also home to certain animals that can be sensitive to noise. Figure 10- 1354 shows the aircraft noise contours generated by the Palo Alto Municipal Airport based on the 2008
Comprehensive Land Use Plan for Palo Alto Airport
prepared by the Santa Clara County Airport Land Use
Commission.

In March 2024, the City of Palo Alto installed a software monitoring system at the Palo Alto Airport that uses
geofencing technology to track aircraft movements over
East Palo Alto and notify pilots who do not follow voluntary noise abatement procedures. These procedures request
that pilots departing from the runway climb over the bay and reach the area of the Dumbarton Bridge before
turning left to fly south or to the Peninsula. Nearly all flights in 2024 complied with noise abatement rules, with only 35 violations documented out of 150,123 flight
operations, or a compliance rate of 99.98 percent.

Palo Alto Airport’s Long-Range Facilities and Sustainability Plan intends to address improvements related to noise
generated by this airport, although, as of January 2026, this effort is on pause. Based on City Council feedback at the September 16, 2024, study session and to meet
constraints not to expand the airport’'s footprint, City staff are reconsidering planning alternatives while making nearterm progress on leaded fuel and noise issues.

The Union Pacific Railroad tracks (Dumbarton Rail Corridor) are located along the northern boundary of the Ccity.

These tracks are currently not in use, although there are plans to extend commuter rail service between the
Peninsula and the East Bay for passenger service. The
Dumbarton Rail project, which would provide commuter
rail service across the bay between the Peninsula and the East Bay, has been under study since the early 2000s. The 2017 Dumbarton Transportation Study recommended a
phased approach that includes rail shuttle service between Redwood City and Newark as a medium-term option
(2025-2030), with potential long-term extension to Union City and integration with the Caltrain mainline. SamTrans is conducting the Reimagine Dumbarton Busway Feasibility
Study (2025-2027) to evaluate converting the unused
Dumbarton freight railroad corridor to provide bus service and improvements for people biking and walking. The
study area extends from University Avenue in East Palo
Alto west to Redwood City Transit Center, serving the
communities of Southeast San Mateo County, including
East Palo Alto, Belle Haven, Redwood City, Atherton, and North Fair Oaks. Should commuter rail service or other
significant intensification of rail use be initiated, noise impacts on adjacent residential areas would need to be
addressed through appropriate noise barriers and
mitigation measures.
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Commercial and industrial operations are the primary
stationary noise sources that make a significant local
contribution to community noise levels. Such uses can
generate noise due to the regular operation of equipment, including fans, blowers, chillers, compressors, boilers, pumps, and air conditioning systems that may run
continuously. Other intermittent sources of noise include horns, buzzers, and loading activities. In general, these stationary noise sources are often located in areas that are isolated from noise sensitive land uses. However, the
possibility of sensitive development encroaching on some of these stationary noise sources remains, which could
result in some land use conflicts.

Noise sources that affect sensitive receptors within the community also include commercial land uses or those
normally associated with and/or secondary to residential development. These include entertainment venues,
nightclubs, outdoor dining areas, gas stations, car washes, fire stations, drive-thru restaurants, air conditioning units, swimming pool pumps, residential gatherings or parties, school playgrounds, athletic and music events, and public parks. These non-transportation noise sources are local and typically only affect their adjacent neighbors.

Another source of noise in East Palo Alto relates to
intermittent construction activities. Construction noise can be significant for short periods of time at any particular location as a result of public improvement projects, private development projects, remodeling, etc. The highest
construction noise levels are normally generated during grading and excavation, with lower noise levels occurring during building construction. Each project is required to follow the hours of construction activity stated in its Municipal Code.
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Figure 10-12 13: - Existing (2015) Traffic Noise
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Figure 10-1134: 2040 Future Plus Project Traffic Noise Contours 204
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Figure 10-1415: Palo Alto Airport Noise Contours
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Goals and Policies
Ground-borne Vibration
Ground-borne vibration consists of rapidly fluctuating
motions or waves with an average motion of zero. In
urban environments, sources of ground-borne vibration
include construction activities such as pile driving and the movement of heavy equipment, light and heavy rail
transit, and heavy trucks and buses. Low-level
vibrations at a structure frequently cause irritating
secondary vibration, such as a slight rattling of
windows, doors, or stacked dishes. The rattling sound
can give rise to exaggerated vibration complaints, even though there is very little risk of actual structural
damage.

There are currently no active rail lines within the City of East Palo Alto; however, Union Pacific reserves the right to run freight operations on these tracks and there are plans to extend commuter rail service between the
Peninsula and the East Bay as previously noted.

Ground-borne vibration would occur in areas adjacent
to the rail lines when railroad trains pass through East Palo Alto. Ground vibration levels along the railroad
corridor would be proportional to the speed and weight
of the trains, as well as the condition of the tracks, train engine, and car wheels. Vibration levels resulting from railroad trains vary by site but are generally perceptible within 100 feet of the tracks.

Construction activities such as demolition, site
preparation, excavation, and foundation work can
generate groundborne vibration at land uses adjoining
construction sites. Impact pile driving has the potential of generating the highest ground vibration levels and is of primary concern to structural damage. Other project
construction activities, such as caisson drilling, the use of jackhammers, rock drills, and other high-power or
vibratory tools, and rolling stock equipment (tracked
vehicles, compactors, etc.) can generate substantial
vibration levels in the immediate vicinity.

Options for Noise Reduction
Because ground transportation noise is the dominant
source of noise in East Palo Alto, it is unlikely that
proposed actions would cause a substantial increase in
noise in the community. There is currently ongoing
research on the effects of different types of pavement
surfaces on the noise generated by vehicular traffic. The interaction of tires and pavement is the main source of traffic noise. The City of East Palo Alto has no
jurisdiction over the noise generated by automobiles,
the types of tires drivers select, etc., but the City can select the type of pavement that it uses to repave its
streets. The consideration of quiet pavement surfaces
in the City’s repaving plans provides an opportunity to make a noticeable reduction in traffic noise along City streets in East Palo Alto. As part of the Ravenswood/4
Corners (RBD) Specific Plan Update (2024), mitigation
measures are included to address noise, such as “quiet” construction equipment models and noise- control
blanket barriers for impact piling driving. In addition, future development projects will be required to pay
their fair- share contribution toward installing quieter pavement types along designated roadway segments
within the Pplan Aarea.

Placing residents in proximity to non-residential land
uses can result in isolated noise problems. For instance, music played at outdoor dining areas or bars can annoy
adjacent residences and be a source of ongoing
complaints. Other urban noise sources, such as the
collection of large garbage dumpsters early in the
morning, the noise of heating, ventilating, and air
conditioning equipment, and outdoor maintenance
activities, are all more frequent in an urban setting. The purpose of a quantitative noise ordinance is to address these types of issues. Reviewing and updating
applicable City ordinances is something the City could
consider in the future if the change in land use patterns results in conflicts that cannot be resolved through
existing regulations.

The most common noise issue that is likely to be faced
by the City can be addressed as it has been historically by evaluating land use proposals in noisy areas and
incorporating noise control treatments to these
projects.
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Goal SN-1236. Minimize the effects of
noise through proper land use
planning.

Intent: To ensure that new noise-sensitive land uses in the City are located in a compatible noise environment
or adequately appropriately mitigated in order to
provide a compatible exterior and interior noise
environment.

Policies:
1236.1 Noise standards. Use the Interior and
ExteriorExterior and Interior Noise Standards
(Table 10-1 and Table 10-2) for transportation
noise sources. Use the City’s Noise Ordinance for
evaluating non-transportation noise sources
when making planning and development
decisions. Require that applicants demonstrate
that the noise standards will be met prior to
project approval and include Conditions of
Approvals to ensure the standards will be met.

13.2 Updates to noise standards. Periodically, during
comprehensive General Plan updates or more
often as needed, review the City’s noise
standards. Update the standards and conduct
new noise studies as necessary to ensure noise
levels remain safe and compatible with the
community.
1236.2 3 Compatibility standards. Utilize
noise/land use compatibility standards and the
Noise Ordinance as guides for future
development decisions.
1236.34 Noise control. Provide noise control measures,
such as berms, walls, and sound attenuating
construction in areas of new construction or
rehabilitation.
123.6.4 5 Vibration impacts. The City shall
require new development to minimize vibration
impacts to adjacent uses during demolition and
construction. For sensitive historic structures, a
vibration limit of 0.08 in/sec PPV will be used to
minimize the potential for cosmetic damage to
the building. A vibration limit of 0.30 in/sec PPV
will be used to minimize the potential for
cosmetic damage at buildings of normal
conventional construction.
1326.5 6 Airport-adjacent land uses. Maintain
the nonresidential designation for land near the
airport in order to prevent new noise- sensitive
residential uses from being constructed in areas
with excessive aircraft noise and to ensure land
use compatibility with Palo Alto Airport
operations and safety zones, as defined in the
Santa Clara County Comprehensive Land Use Plan
for Palo Alto Airport.

Goal SN-1347. Minimize
transportation- and nontransportation-related noise impacts, especially on noise-sensitive land uses.

Intent: To maintain and improve the noise environment
at noise-sensitive land uses throughout the Ccity.

Policies:
1347.1 Noise ordinance. Continually enforce and
periodically review the City’s Noise Ordinance for
adequacy (including requiring construction
activity to comply with established work schedule
limits). Amend as needed to address community
needs and development patterns.
1347.2 CEQA acoustical analysis. Require an
acoustical analysis to evaluate mitigation
measures for noise generating projects that are
likely to cause the following criteria to be
exceeded or to cause a significant adverse
community response:
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• Cause the Ldn/CNEL at noise-sensitive
uses to increase by 3 dBA or more and
exceed the “normally acceptable” level.
• Cause the Ldn/CNEL at noise- sensitive
uses to increase 5 dBA or more and
remain
“normally acceptable”.
1347.3 Highway noise barriers. Require Ensure that
noise barriers are included considered in the
design of roadway, freeway, and rail
improvements to mitigate significant noise
impacts. Support efforts by Caltrans and other
transportation providers to provide acoustical
protection for noise sensitive development
(especially along Highway 101). Preserve existing
vegetation that serve as noise buffers along
transportation corridors. Where such buffering is
absent, encourage new vegetative buffers that
are consistent with the City’s urban forestry and
drought resilience goals.
134.7.4 Vehicle noise standards. Coordinate with the
California Highway Patrol and other law
enforcement agencies to enforce noise standards
for cars, trucks, and motorcycles.
1347.5 Traffic and truck noise. Regulate traffic flow to enforce speed limits to reduce traffic noise.

Periodically evaluate and enforce established
truck and bus routes to avoid noise impacts on
sensitive receptors.
1347.6 Coordination with Airport Land Use
Commission. Work with the Santa Clara County
Airport Land Use Commission and the Palo Alto
Airport to reduce aircraft noise in East Palo Alto.
ensure land use decisions in East Palo Alto are
consistent with the Airport Comprehensive Land
Use Plan, including noise compatibility standards
and safety zones.
1347.7 Site design review. Utilize site design review to identify potential noise impacts on new
development, especially from nearby
transportation sources. Encourage the use of
noise barriers (walls, berms, or landscaping),
setbacks and/or other buffers.
1347.8 Quiet asphalt. Consider a “quieter” pavement
that also meets other criteria established by the
City for pavements for use in resurfacing
roadways. Encourage its use in future capital
projects. Projects located within the
Ravenswood/4 Corners Specific Plan area are
required to pay their fair- share contribution
towards quieter pavement installation.
1347.9 Noise barriers along future rail. Should
commuter transitrail service along the
Dumbarton Corridor or other significant
intensification of rail use be initiated, the City
shall require that work with SamTrans, Union
Pacific, and other responsible agencies to require
construction of noise barriers adjacent to existing
unprotected residential areas near the rail line.
1347.10 Airport noise. Work with Palo Alto Airport, San Francisco International Airport, San Carlos
Airport, and the Federal Aviation
Administrationregional partners to minimize
aircraft noise impacts ongeneral aviation and
commercial airport noise over East Palo Alto
through flight path routing, time-of-day
operation considerations, community
notifications, and voluntary noise abatement
procedures.
1347.11 Construction noise. The City shall require that contractors use available noise suppression
devices and techniques and limit construction
hours near residential uses. Reasonable noise
reduction measures shall be incorporated into
the construction plan and implemented during all
phases of construction activity to minimize the
exposure of neighboring properties. The City
considers significant construction noise impacts
to occur if a project located within 500 feet of
residential uses or 200 feet of commercial or
office uses would:
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• Involve substantial noise generating
activities (such as building demolition,
grading, excavation, pile driving, use of
impact equipment, or building framing)
continuing for more than 12 months.

For such large or complex projects, a construction noise logistics plan that specifies hours of construction, noise and vibration minimization measures, posting or
notification of construction schedules, and designation of a noise disturbance coordinator who would respond
to neighborhood complaints will be required to be in
place prior to the start of construction and
implemented during construction to reduce noise
impacts on neighboring residents and other uses. A
typical construction noise logistics plan would include, but not be limited to, the following measures to reduce construction noise levels as low as practical:
• Limit construction activity to weekdays between
7:00 am and 76:00 pm and Saturdays and holidays
between 9:00 am and 75:00 pm, with no
construction on Sundaysthe hours specified in the
Municipal Code;
• Utilize ‘quiet’ models of air compressors and other
stationary noise sources where technology exists;
• Equip all internal combustion engine-driven
equipment with mufflers, which are in good
condition and appropriate for the equipment;
• Locate all stationary noise-generating equipment,
such as air compressors and portable power
generators, as far away as possible from adjacent
land uses;
• Locate staging areas and construction material
areas as far away as possible from adjacent land
uses;
• Prohibit all unnecessary idling of internal
combustion engines;
• If impact pile driving is proposed, multiple pile
drivers shall be considered to expedite
construction. Although noise levels generated by
multiple pile drivers would be higher than the
noise generated by a single pile driver, the total
duration of pile driving activities would be reduced;
• If impact pile driving is proposed, temporary noise
control blanket barriers shall shroud pile drivers or
be erected in a manner to shield the adjacent land
uses. Such noise control blanket barriers can be
rented and quickly erected;
• If impact pile driving is proposed, foundation pile
holes shall be pre-drilled to minimize the number
of impacts required to seat the pile. Pre-drilling
foundation pile holes is a standard construction
noise control technique. Pre-drilling reduces the
number of blows required to seat the pile. Notify
all adjacent land uses of the construction schedule
in writing;
• Designate a "disturbance coordinator" who would
be responsible for responding to any local
complaints about construction noise. The
disturbance coordinator will determine the cause
of the noise complaint (e.g., starting too early, bad
muffler, etc.) and will require that reasonable
measures warranted to correct the problem be
implemented; and
• Conspicuously post a telephone number for the
disturbance coordinator at the construction site
and include it in the notice sent to neighbors
regarding the construction.

Goal SN-1458. Coordinate land use
planning to prevent new odor
complaints.

Intent: To avoid conflicts related to bad odors, especially between incompatible uses.
1458.1 Identify potential for odor complaints. Use
BAAQMD Odor Screening Distances or Cityspecific screening distances to identify odor potential. Evaluate odors from sources within
these screening distances based on odor
potential, wind conditions, setback distance, and
receptor type.
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1458.2 Odor sources. Prohibit new sources of odors
that have the potential to result in frequent odor
complaints unless it can be shown that potential
odor complaints can be mitigated.
1458.3 Sensitive receptors near odor sources.

Prohibit sensitive receptors from locating near
odor sources where frequent odor complaints
would occur, unless it can be shown that
potential odor complaints can be mitigated.
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Table 10-1. Exterior Noise Standards –
Receiving Land Use: Single or Multiple Family
Residence, School, Hospital, Church, or Public
Library Properties
Category
Cumulative
Number of
Minutes in
Any One
Hour Time
Period
Daytime
(7 am to
10 pm)
Nightime
(10 pm to
7 am)
1 30 55 dBA 50 dBA
2 15 50 dBA 55 dBA
3 5 65 dBA 60 dBA
4 1 70 dBA 60 dBA
5 0 75 dBA 70 dBA

3.6 Development Impact Fee. Coordinate with
MPFPD in examining an impact fee on new
development in order to help ensure provision of
services in the event of demand increases.

Table 10-1. Interior and Exterior Noise Standards
Land Use
Noise Standards1
Interior2, 3 Exterior
Residential – Single family, multifamily, duplex, mobile home CNEL 45 dB CNEL 65 dB4 Residential – Transient lodging, hotels, motels, nursing home, hospitals CNEL 45 dB CNEL 65 dB4 Private offices, church sanctuaries, libraries, board rooms, conference rooms, theaters, auditoriums, concert halls, meeting halls, etc. Leq(12) 45 dB(A) - Schools Leq(12) 45 dB(A) Leq(12) 67 dB(A)5
General offices, reception, clerical, etc. Leq(12) 50 dB(A) - Bank lobby, retail store, restaurant, typing pool, etc. Leq(12) 55 dB(A) - Manufacturing, kitchen, warehousing, etc. Leq(12) 65 dB(A) - Parks, playgrounds - CNEL 65 dB5
Golf courses, outdoor spectator sports, amusement parks - CNEL 70 dB5 Notes:

1. CNEL: Community Noise Equivalent Level; Leq (12):

The A-weighted equivalent sound level averaged over a
12-hour period (usually the hours of operation).

2. Noise standard with windows closed. Mechanical
ventilation shall be provided per UBC requirements to
provide a habitable environment.

3. Indoor environment excluding bathrooms, toilets,
closets, and corridors.

4. Outdoor environment limited to rear yard of single
family homes, multifamily patios, and balconies (with a depth of 6’ or more) and common recreation areas.

5. Outdoor environment limited to playground areas,
picnic areas, and other areas of frequent human use.

Source: Title 24, California Code of Regulations
Notes:

1. In the event the measured background noise
exceeds the applicable noise level standard in any
category above, the applicable standard shall be
adjusted in five dBA increments so as to
encompass the background noise level.

2. Each of the noise level standards specified above
shall be reduced by five dBA for simple tone
noises, noises consisting primarily of speech or
music, or for recurring or intermittent impulsive
noises.

1.3. If the intruding noise source is continuous and
cannot be reasonably stopped for a period of time
whereby the background noise level can be
measured, the noise level measured while the
source is in operation shall be compared directly
to the noise level standards in Table 10-1.

Table 10-2. Interior Noise Standards – Dwelling
Unit
Category
Cumulative
Number of
Minutes in
Any One
Hour Time
Period
Daytime
(7 am to
10 pm)
Nightime
(10 pm to
7 am)
1 5 45 dBA 40 dBA
2 1 50 dBA 45 dBA
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3 0 55 dBA 50 dBA
Notes:

4. In the event the measured background noise
exceeds the applicable noise level standard in
any category above, the applicable standard
shall be adjusted in five dBA increments so as
to encompass the background noise level.

5. Each of the noise level standards specified
above shall be reduced by five dBA for simple
tone noises, noises consisting primarily of
speech or music, or for recurring or
intermittent impulsive noises.

2.6. If the intruding noise source is continuous and
cannot be reasonably stopped for a period of
time whereby the background noise level can
be measured, the noise level measured while
the source is in operation shall be compared
directly to the noise level standards in Table
10-2.
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CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-1

9. Infrastructure, Services, and
FaciliƟes
Overview
This chapter encompasses the physical
infrastructure, City-owned faciliƟes, and civic
services of the City of East Palo Alto. It includes
goals, policies, and service standards for City-owned
properƟes, public services (police and emergency
response), and schools.

Statutory Requirements
While an Element addressing infrastructure, services, and public faciliƟes is not required, this Element provides vital policy basis to guide shorter-term documents, such as the capital improvements program and the annual
capital budget. The Element offers generalized long-term policies grounded in realisƟc analyses of exisƟng capacity, future demand, and financing opƟons.

Specifically, this chapter addresses the goals and policies relaƟng to stormwater drainage, water supply and
demand, uƟliƟes & telecommunicaƟons, recycling/solid
waste, and climate change adaptaƟon and miƟgaƟon.

This chapter also addresses other topics related to
infrastructure, public faciliƟes, and public services. The CirculaƟon Element includes addiƟonal content related
to transportaƟon and street infrastructure. ’s
infrastructure, community buildings, and essenƟal
services. The City prepared a Climate Change
Vulnerability Assessment (2025) which idenƟfied
flooding, extreme heat, sea level rise, and severe
weather as priority hazards that threaten criƟcal faciliƟes and service delivery. The assessment reveals that uƟlity and communicaƟon services face heightened
vulnerability due to limited redundancy, while Cityowned faciliƟes and emergency services are at risk from infrastructure damage that could disrupt emergency
response capabiliƟes during climate events. These
climate vulnerabiliƟes necessitate proacƟve planning to ensure infrastructure resilience and conƟnuity of
essenƟal services, parƟcularly for disadvantaged
communiƟes that face disproporƟonate impacts from
climate hazards. AddiƟonal informaƟon about hazards in
East Palo Alto is included in the Safety and Noise
Element. The full results of the Vulnerability Assessment are available as Appendix B to the Safety and Noise
Element.

Issues and OpportuniƟes
Stormwater System
The storm drainage system in the city is composed of
networks of pipes, channels, storage ponds, and pump
staƟons which outlet to San Francisquito Creek, and the San Francisco Bay. Figure 9-1 shows the exisƟng system
layout. Stormwater in East Palo Alto drains into two
major drainage systems: the Runnymede Storm Drain
System and the O’Connor Storm Drain System. Due to its
proximity to the San Francisco Bay, porƟons of the
drainage system are influenced by Ɵde. The majority of
East Palo Alto is low lying and over half of the drainage area is reliant on pumping from the O’Connor pump
staƟon.

As several storms have demonstrated, much of the city is vulnerable to flood damage during even regular storm
events. Since 1940 there have been eight major flood
events, and over half of the city (56 percent) is in areas designated for an elevated risk for flooding. The Safety Element provides comprehensive hazard mapping and
detailed analysis of flooding risks, including hazards from sea level rise and increases in groundwater levels that will increasingly affect the City's stormwater
infrastructure.
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CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-2
The City has a Storm Drain Master Plan, adopted in 2015, that guides the development of a comprehensive
approach to storm drain faciliƟes. As of 2015, many of
the streets in East Palo Alto lack storm drains. Where
storm drains exist, they lack the capacity to handle
stormwater during heavy rain events. During 10- and 20- year storm events in East Palo Alto, storm drains can
overflow, flooding the streets, and in the case of the
1998 floods, parts of the city were effecƟvely stranded.

A heavy rain event in 2012 led to significant flooding in mulƟple parts of the city. In 2022, a low-pressure system brough heavy rainfall over a two-day period, causing
roadway flooding and closures and property damage for
residents living near San Francisquito Creek.

Low-lying areas face extra risk of floods related to levee breaks, ruptures, or overtopping. AddiƟonally, the other infrastructure, such as pump staƟons, are in need of
replacement. This, combined with the overtopping spills from San Francisquito Creek, present significant flooding issues in the city.

A recent study of the drainage system indicated several drainage system issues. The cost of the needed capital
improvements is approximately $37.5 million and
consists of pipe improvements, system cleaning, drainage system expansion and realignments, monitoring and data
collecƟon, a pump staƟon retrofit, and two projects that will require coordinaƟon with the City of Menlo Park: the O'Connor Pump StaƟon Underground Diesel Storage Tank
Piping Upgrades and the O'Connor Pump StaƟon
Improvements (including adding a flow control structure, replacing pump verƟcal shaŌs, and upgrading electrical
systems). EvaluaƟons in June 2017 and January 2024 of
the O'Connor Pump StaƟon indicated that several nearterm improvements are necessary to maintain the pump staƟon’s exisƟng capacity, and several other
improvements are necessary to rehabilitate the pump
staƟon for anƟcipated future condiƟons, especially with the projected impacts of climate change on flood hazards and drainage needs.

In addiƟon to managing stormwater quanƟty and
reducing flood risks, the City has made significant
investments in controlling trash and pollutants in
stormwater runoff, as required by the State Water
Resources Control Board's Municipal Regional Permit
(MRP). These efforts include source controls to prevent trash generaƟon, insƟtuƟonal controls to intercept trash before it enters the storm sewer system, and the
installaƟon of Full Trash Capture systems. The City has installed one such system, known as the SD-9 project, at Newbridge Street and Saratoga Avenue. This project
treats a 772-acre drainage area and is projected to
reduce trash by 16 percent, supporƟng the regional goal of achieving 100 percent city-wide trash capture for
watersheds draining into San Francisco Bay.

Figure 9-1: ExisƟng Storm Drain System
Potable Water Quality and Supply
The City’s potable water system is operated by Veolia
Water North America under contract with the City. The
majority of the City’s water supply is supplied by the San Francisco Public UƟliƟes Commission (SFPUC) Bay
Division Pipelines 1 and 2, as well as two small
independent systems: the Palo Alto Park Mutual Water
Company and the O’Connor Tract Co-Op Water Company.

There are no water storage reservoirs or potable
groundwater sources in the city at this Ɵme (with the
excepƟon of small private water storage at the Home
Depot and IKEA for fire flow needs, and a staƟc water
supply tank at Palo Alto Park Mutual where the Menlo
Park Fire ProtecƟon District can obtain treated water for emergency response). To provide addiƟonal future water
supply and supplement the SFPUC supply, the City is
working to upgrade the Gloria Way Well and develop a
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CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-3
second groundwater well at Pad D, a City-owned parcel
near the Gateway 101 Shopping Center.

According to the exisƟng infrastructure analysis
performed by Schaaf & Wheeler for this General Plan
Update, East Palo Alto has a significant water supply
challenge. The City has a fixed supply guarantee from the SFPUC of 1,264 million gallons (MG) per year. Water
demand in East Palo Alto was 552 MG per year on
average between 2016 and 2020, projected to rise to
1,078 MGF by 2045.

Sewer System
The sanitary sewer system within East Palo Alto is
composed of systems managed by the West Bay Sanitary
District (WBSD), which is an independent agency, and the East Palo Alto Sanitary District (EPASD), which is a
subsidiary district of the City of East Palo Alto. Figure 9-2 shows the boundaries of the two sanitary district service areas within the city limits. The EPASD provides sanitary sewer services for the majority of East Palo Alto and
completed a Sewer Master Plan in July 2025. The EPASD
system consists of approximately 33 miles of gravity
sewer pipelines, with pipe sizes ranging from 6 inches to 30 inches in diameter. A major infrastructure component is the siphon under San Francisquito Creek, which was
realigned in 2017 with two parallel 22-inch pipes. Sewage within the EPASD service area is conveyed by gravity to the Palo Alto Regional Water Quality Control Plant. The West Bay Sanitary District, which serves parts of East Palo Alto and several nearby communiƟes, has approximately
220 miles of gravity sewer pipelines. It sends sewage to the Silicon Valley Clean Water treatment plant in
Redwood City.

Figure 9-2: Sewer/SanitaƟon Districts
Solid Waste and Recycling
East Palo Alto’s solid waste program is operated by South Bayside Waste Management Authority (SBWMA) also
known as RethinkWaste. RethinkWaste member agencies
are serviced by the Shoreway Environmental Center (SEC) which receives, handles, and transfers solid waste and
recyclables collected from SBWMA’s hauler to offsite
shipment into the Ox Mountain Landfill, which primarily accepts solid waste from San Mateo County communiƟes
and San Francisco. The Ox Mountain Landfill has a
maximum permiƩed capacity of 60.5 million cubic yards.

As of December 2021, the landfill had approximately 17.2 million cubic yards of remaining capacity and is projected to cease operaƟons in 2034 based on current disposal
rates. The landfill accepts up to 3,598 tons per day and is the only acƟve Class III municipal solid waste landfill in San Mateo County.11
In 2023, East Palo Alto generated 19,362 tons of solid
waste and recyclable materials annually (approximately
53 tons per day). Of this total, 11,947 tons were disposed at a landfill as solid waste and 7,414 tons were diverted through recycling and organics programs, achieving an
overall diversion rate of 38 percent. This represents East Palo Alto's contribuƟon to the SBWMA's regional waste
management system.
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CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-4
The City's residenƟal diversion rate of 46 percent includes both curbside recycling and organics collecƟon.

Commercial operaƟons achieved a 47 percent diversion
rate through recycling and organics programs. However,
mulƟ-family dwelling diversion rates remain significantly lower at 16 percent, primarily due to limited organics
collecƟon in these properƟes).

The current solid waste generated from East Palo Alto
does not exceed alloƩed capacity for the SBWMA, SEC, or Ox Mountain Landfill. The City and RethinkWaste at large are currently undertaking efforts to increase the landfill diversion rate through improved commercial and
residenƟal solid and organics recycling.

The City has made progress in waste diversion through
expanded organics recycling programs, implementaƟon
of residenƟal food waste collecƟon, and commercial
waste audiƟng programs. These efforts align with
California's Senate Bill (SB) 1383 requirements for organic waste diversion. The City conƟnues to work with
Recology, the contracted waste hauler, to improve
collecƟon services and expand community educaƟon
about proper sorƟng of waste, recycling, and
compostable materials.

Climate Change AdaptaƟon and
MiƟgaƟon
Climate change is a threat to the health and safety of East Palo Alto residents, as well as those in other parts of the region, the state, and the globe. Concerned about the
impact of climate change, California has adopted a wide variety of legislaƟon policies aimed at reducing the
state’s greenhouse gas (GHG) emissions. These include
the California Global Warming SoluƟons Act of 2006 (AB
32), SB 32 (2016), and AB 1279 (2022), which established statewide GHG reducƟon goals for 2020, 2030, and 2045;
SB 375, which requires and encourages sustainable land
use and transportaƟon paƩerns at the regional and local level; and various acƟons by Governors Schwarzenegger,
Brown, and Newsom, and the State AƩorney General’s
office.

Climate adaptaƟon strategies are comprehensively
addressed throughout this General Plan, as required by
State law. The Safety and Noise Element includes detailed policies and implementaƟon acƟons for sea level rise,
flooding, extreme heat, severe weather, drought, and
other climate hazards that directly threaten community
safety and infrastructure. The Safety and Noise Element incorporates the East Palo Alto Vulnerability Assessment (2025) findings and provides specific adaptaƟon
measures tailored to the City's unique vulnerabiliƟes.

This integraƟon ensures that adaptaƟon planning is
embedded in safety and resilience planning rather than
treated as a separate infrastructure concern.

The City parƟcipates in regional climate iniƟaƟves. East Palo Alto is a member of OneShoreline, also known as
the San Mateo County Flood and Sea Level Rise
Resiliency District, which coordinates flooding and sea level rise adaptaƟon planning across San Mateo County.

The City coordinates the County’s Sustainability
Department climate programs. The City also parƟcipates
in OneWatershed, a comprehensive framework
addressing shared climate risks to water infrastructure across San Mateo County, and the San Francisquito Creek Joint Powers Authority’s flood protecƟon efforts that
integrate both adaptaƟon and carbon sequestraƟon
through wetland restoraƟon and green infrastructure.

Climate miƟgaƟon—the reducƟon of GHG emissions that
cause climate change—is addressed in this General Plan
through policies related to energy efficiency, sustainable transportaƟon, waste reducƟon, green infrastructure,
development paƩerns, and water conservaƟon.

The City adopted a Climate AcƟon Plan in 2011 and
prepared an update in 2023 outlining strategies at both the municipal and community-wide level to miƟgate and
adapt to climate change. In addiƟon to energy-related
topics like energy efficiency and use of renewable energy, the Climate AcƟon Plan also points to material re-use and recycling, public transportaƟon, bicycle and pedestrian faciliƟes, urban green spaces, and compact development
paƩerns as important strategies in reducing GHG
emissions. The 2023 update sets a goal for East Palo Alto to reduce its per-person GHG emissions to 55 percent
below 2005 levels by 2030, with an aspiraƟonal goal of
achieving carbon neutrality by 2045. The City is acƟvely implemenƟng the Climate AcƟon Plan through projects
focused on sustainable homes and buildings (including
building electrificaƟon and energy-efficiency
improvements), transportaƟon improvements
(expanding access to bikes, transiƟoning the City fleet to 216
CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-5
electric vehicles), waste reducƟon (composƟng outreach
and sustainable purchasing), and community resilience
(tree planƟng, green infrastructure, and flood
preparaƟon). The City provides annual implementaƟon
updates and coordinates closely with community
organizaƟons, the Climate Change Community Team, and
regional partners to advance climate acƟon.

Schools
The public schools in East Palo Alto are shown in Table 9-

1. From kindergarten through eighth grade, East Palo Alto students aƩend school in the Ravenswood City School
District (RCSD), which includes schools within and
outside the City of East Palo Alto. Most students aƩend RCSD schools in East Palo Alto, but many also aƩend one of the two RCSD elementary schools in Menlo Park
(Willow Oaks and Belle Haven). The Primary School, a K-8 private school, is planning to shut down at the end of the 2025-26 school year. Future plans for this space are
undetermined. Elementary and middle schools are
distributed throughout the city, with a cluster of several adjacent schools concentrated along Pulgas Avenue
forming an emerging educaƟon hub in the Weeks
neighborhood.

Sequoia Union High School District (SUHSD) serves most
of the city’s public high-school students. As of fall 2015, all students in the Sequoia Unified School District from East Palo Alto aƩend Menlo-Atherton High School
(Atherton), unless they chose to go to a different school in the district. School assignment is no longer addressbased (previously, EPA students were divided amongst several high schools). The former high school in East Palo Alto burned down in the early 1970s.

Table 9-1: Public Schools Within East Palo Alto
School Address City Grades
Preschool
Ravenswood Child Development Center 951 O’Connor Street East Palo Alto Pre-K Elementary Schools
Edison Brentwood Academy 2086 Clarke Street East Palo Alto K-5 East Palo Alto Charter School (Charter) 1286 Runnymede Street East Palo Alto K-5 Combined Elementary & Middle Schools
Costaño Elementary School & 49ers Academy 2695 Fordham Street East Palo Alto K-8 Middle Schools
Cesar Chávez Academy 2450 Ralmar Avenue East Palo Alto 5-8 Ronald McNair Academy 2033 Pulgas Avenue East Palo Alto 6-8 High Schools
KIPP Esperanza (Charter) 1039 Garden Street East Palo Alto 6-12 Eastside College Preparatory School (Charter) 1041 Myrtle Street East Palo Alto 9-12 AlternaƟvely, high school-age students may apply to one of two public charter schools in the city – KIPP Esperanza High School or East Palo Alto Academy – or the private
high school, Eastside College Preparatory School, located at 1041 Myrtle Street (not shown in the table).

All the local school districts are bound by the 1986
Voluntary Transfer Plan (VTP), wherein the school
districts agreed to reduce racial isolaƟon. The Tinsley Voluntary Transfer Plan allows minority students in the RCSD to transfer to one of seven local school districts:

Belmont-Redwood Shores, Las Lomitas, Menlo Park, Palo
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CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-6
Alto, Portola Valley, San Carlos, and Woodside.

Conversely, non-minority students in those seven local
school districts may transfer into Ravenswood.

The 2025 East Palo Alto Vulnerability Assessment
idenƟfied several RCSD schools as being located in areas vulnerable to climate hazards, including flooding,
extreme heat, and potenƟal liquefacƟon during seismic
events. The concentraƟon of schools along Pulgas
Avenue presents both opportuniƟes for creaƟng an
integrated educaƟon campus with shared faciliƟes and
challenges related to climate resilience and emergency
preparedness. CoordinaƟon between the City and school
districts is essenƟal to ensure school faciliƟes serve dual purposes as community centers and emergency shelters
when appropriately equipped and maintained.

City-Owned FaciliƟes
The City of East Palo Alto owns and operates a number of faciliƟes throughout the city, including City Hall and City offices, the David Lewis Re-entry Program, the Senior
Center, the Police StaƟon, and the CorporaƟon Yard (see Table 9-2).

The City does not own its own City Hall or space for many of its offices. City Hall is currently located at 2415
University Avenue in space leased from San Mateo
County. The City Hall building includes City Council
Chambers and many of the City offices, as well as the
East Palo Alto branch of the San Mateo County Library
System. The library includes a homework center for aŌerschool tutoring, story Ɵmes, and computer classes. The current 8,000-square-foot library equates to 275 square feet per 1,000 residents.

The City owns the David Lewis Community Re-entry
Program building at 2277 University Avenue, as well as
the building at 1960 Tate, which currently houses the
Community Development Department. The City leases
the Public Works Maintenance Division’s CorporaƟon
Yard at 160 Tara Road. The Senior Center on University
Avenue and Bell Street is owned by the City but managed by the East Palo Alto Senior Center, Inc., a nonprofit
1 2003 East Palo Alto RecreaƟon and Community Services Strategic Plan oversees crime analysis and records, among other duƟes. Some large property owners – such as Equity ResidenƟal on the Westside – provide their own private security services, but most of the public rely on City police services. Even with the presence of private providers, EPAPD conƟnues to police the Westside and respond to calls for service at all Equity properƟes. organizaƟon with an execuƟve director and a board of
directors.1
The City provides an on-site nutriƟon
supervisor for the Congregate Lunch Program, and
security and transportaƟon services to the Senior Center.

Flooding along San Francisquito Creek.
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CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-7
Table 9-2: City FaciliƟes
Facility Name Operator/Facility Type
FaciliƟes Operated and Owned:

Jack Farrell Park City Park
MLK Park City Park
O’Connor Pump StaƟon Drainage DistribuƟon Pump House
FaciliƟes Operated, but not Owned (Lease):
141 Demeter Street Police Department
219 Demeter Street Police Department
150 Tara Road CorporaƟon Yard
FaciliƟes Occupied, Not Operated or Owned (Lease):
2415 University Avenue City AdministraƟon/Housing
FaciliƟes Owned, Not Operated:
550 Bell Street Land and Pool, Pool House Operated by YMCA 550 Bell Street Senior Center Operated by Senior Inc.
2277 University Avenue Operated by SMC, Reentry
Former RDA FaciliƟes in DissoluƟon Trust - To be Transferred to City (Owned /Operated) Cooley Landing City Park
Pad “D” Well Groundwater Well
Rail Spur Trail
1960 Tate Street CEDE/PW
1798 Bay Road Former Clinic
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CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-8
Goals and Policies
Goal ISF-1. Manage stormwater safely,
efficiently, and sustainably.

Intent: To reduce dangers from flooding, protect
community safety and property, and provide wellmaintained infrastructure to the community while reducing the negaƟve environmental impacts of storm
run-off on creeks and the Bay.

Policies:

1.1 NPDES compliance. Ensure compliance with all
NPDES requirements for liƩer control, dumping,
pollutants of control, business operaƟons, and
new/re-development.

1.2 On-site stormwater management. Encourage
development projects to manage stormwater on
site to reduce burdens on the City’s stormwater
system. Whenever possible, stormwater should be
infiltrated, evapotranspirated, reused or treated
on-site in other ways that improve stormwater
quality and reduce flows into the storm drain
system.

1.3 Stormwater infrastructure for new development.

Require development projects to pay for their share
of new stormwater infrastructure or improvements
necessitated by that development.

1.4 Stormwater re-use and recycling. Encourage
innovaƟve ways of capturing and reusing
stormwater for non-drinking purposes to reduce
the use of potable water, including the creaƟon of a
recycled water system and installaƟon of purple
pipe in private and public projects.

1.5 CollaboraƟve stormwater management.

Encourage collaboraƟve, integrated stormwater
management between mulƟple property owners
and sites.

1.6 Green infrastructure in public rights-of-way.

Require installaƟon of green infrastructure
elements, including bioretenƟon areas, pervious
surfaces, and diverse naƟve trees when public
rights-of-way undergo major modificaƟons.

PrioriƟze improved stormwater management
through integraƟon of higher-capacity trunk lines,
capture devices, and bioretenƟon faciliƟes.

1.7 Regional and local collaboraƟon. Collaborate with
Palo Alto, Menlo Park, the San Francisquito Creek
Joint Powers Authority and other jurisdicƟons and
agencies in the watershed to reduce and remove
contaminants from stormwater runoff.

1.8 Stormwater best pracƟces. Require the use of
stormwater best management pracƟces for
retenƟon and water quality control. Implement
flood-control measures that incorporate green
infrastructure to manage stormwater runoff while
protecƟng water quality and habitat.

1.9 Stormwater and flooding. Integrate stormwater
management efforts with flood control efforts,
seeking synergies and innovaƟve strategies for
stormwater treatment to reduce flood risks and
volumes.

1.10 Stormwater System Resilience to Sea Level Rise.

Explore upgrading and adapƟng stormwater
infrastructure to account for projected sea level rise
and associated groundwater changes.

Improvements may include increasing system
capacity, protecƟng pipes and faciliƟes from
saltwater intrusion and corrosion, enhancing pump
and ouƞall performance, and ensuring regular
maintenance and monitoring to prevent system
failure under future climate condiƟons.

1.11 Storm Drain Master Plan. ConƟnue to implement
the adopted East Palo Alto Storm Drain Master
Plan. Seek funding sources to complete the
idenƟfied capital improvements.
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CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-9

1.12 Assessment district. Consider avenues for
sustainable funding of landscaping and
maintenance to fund the maintenance of the storm
water conveyance and treatment systems.

1.13 Ravenswood stormwater management. All new
projects in the Ravenswood TOD Specific Plan Area
must follow the stormwater policies established in
Goal LU-9: Hydrological Context in the plan.

Guidance in the Specific Plan supersedes policies
from this General Plan.

1.14 Community-Informed Flood MiƟgaƟon. Engage
community members, parƟcularly in historically
flood-impacted areas, in idenƟfying drainage
system issues and developing targeted soluƟons
that incorporate local knowledge with technical
experƟse.

Goal ISF-2. Ensure a sustainable, clean,
long-term water supply.

Intent: To address the City’s lack of water supply, and insƟtute long-term strategies to sustainably manage
limited water resources.

Policies:

2.1 Water planning. ConƟnue to maintain a Water
System Master Plan, Urban Water Management
Plan, and water supply blueprint.

2.2 Water supply infrastructure. ConƟnue to improve
infrastructure to ensure the provision of a clean,
reliable citywide water supply sufficient to serve
exisƟng and planned development.

2.3 New water sources. AcƟvely seek to secure
addiƟonal water supply from SFPUC, groundwater
sources, neighboring ciƟes, or other available
sources. Securing addiƟonal water supply and
adding water storage faciliƟes should be a City
priority to ensure RHNA goals are being met.

2.4 Priority improvement areas. PrioriƟze water
improvements in areas idenƟfied in the Land Use
Element as areas of growth/change and economic
acƟvity generators, parƟcularly the Westside,
University Avenue and Bay Road, the Gateway 101
area, and the Ravenswood TOD Specific Plan area.

2.5 Water infrastructure for new development.

Require development projects to pay for their share
of new water infrastructure or improvements
necessitated by that development, including but
not limited to water supply, storage, and
conservaƟon: and recycled water.

2.6 Water supply for new development. Require new
or intensified development to demonstrate that
adequate water is available before project
approval. Before new or intensified development
projects are approved, the development proponent
must provide the City with enforceable, verifiable
proof that adequate water supply exists to supply
the new or intensified development. The
enforceable proof can take three forms:
• Depending on the locaƟon of the
development, a will-serve leƩer or similar
instrument from the City of East Palo Alto,
the Palo Alto Park Mutual Water Company,
or the O’Connor Tract CooperaƟve Water
Company.
• A verifiable recordable water demand offset
project or program that ensures that there is
no net increase in new water demand.
• Verifiable and enforceable proof that the
developer has secured new water supplies
necessary to serve the project.

2.7 Municipal water conservaƟon and efficiency. Seek
to reduce municipal water use through the
following strategies:
• Implement aggressive indoor and outdoor
water efficiency measures in all new city
developments, substanƟal rehabs, and
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CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-10
remodels. For private development projects,
require efficient irrigaƟon systems to be
inspected prior to occupancy for adherence
to the Model Water Efficient Landscape
Ordinance (MWELO).
• PrioriƟze water efficiency upgrades to
exisƟng buildings, such as water efficient
fixtures.
• Reduce potable water used for parks, by
planƟng drought-tolerant species and
implemenƟng other water saving pracƟces.

2.8 Citywide water conservaƟon and efficiency.

Encourage and promote community water
conservaƟon and efficiency efforts, including indoor
and outdoor efforts that exceed CalGreen
requirements.

2.9 ConservaƟon partnerships. ConƟnue to work with
BAWSCA to create and promote water conservaƟon
rebates (such as for installing low flow toilets in
exisƟng residences, high efficiency front load
washing machines and distribuƟng low flow shower
heads). Encourage residents to take advantage of
the Bay Area Water Supply & ConservaƟon Agency
(BAWSCA) Lawn Be Gone Program (or other similar
rebates).

2.10 Sustainable Water Supplies. Work with San
Francisco Public UƟliƟes Commission to prepare for
a reduced long-term water supply resulƟng from
more frequent and severe drought events to
implement extensive water conservaƟon measures
and ensure sustainable water supplies, including
fire-suppression needs.

2.11 Public educaƟon about water. Educate the public,
in partnership with BAWSCA and , community
partners, and other CBOs regarding water
conservaƟon, water efficiency, graywater use,
stormwater reuse, water-efficient planƟng and
outdoor efficiency, and other efforts to conserve
water. Include informaƟon about water sources and
any relevant updates to programs from the Water
System Master Plan and Urban Water Management
Plan. Provide all outreach materials in mulƟple
languages.

2.12 Groundwater Management. Prohibit new private
groundwater wells and work with regional partners
to implement groundwater recharge strategies that
protect and enhance local aquifers.

2.13 Maximizing infiltraƟon. Consider requiring all new development to apply stormwater best
management pracƟces (BMPs) where feasible, such
as providing roof catchment systems, irrigated
landscaping, and permeable pavements (where
feasible), or other means to enhance onsite
infiltraƟon of stormwater runoff or landscape
irrigaƟon water.

2.14 Rainwater Catchment Systems. Construct
rainwater catchment systems to recharge
groundwater in government rights-of-way, where
feasible.

2.15 Water ConservaƟon Retrofits and Community
Partnerships. Increase drought resilience through
the following strategies:
• Retrofit City-owned landscapes to increase
the amount of drought-resistant and/or
naƟve plant landscaping.
• Partner with community-based
organizaƟons and residents to install rain
garden and water cistern systems for lowincome homeowners in East Palo Alto. • Pursue grant funding and other resources to
expand water conservaƟon programs
citywide.

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CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-11
Goal ISF-3. Provide a well-maintained
sewer system for the community.

Intent: To protect human health, protect ecological
resources and water quality, and provide well-maintained services for new and exisƟng development.

Policies:

3.1 Sewer system maintenance. Ensure sewers
maintained by the City through the East Palo Alto
Sanitary District are operaƟonal, in good working
order, and can remain operaƟonal under future sea
level rise and emergent groundwater condiƟons.

Work with the West Palo Alto Sanitary District to
ensure similar standards for sewers maintained by
that agency.

3.2 Sewer infrastructure for new development.

Require development projects to pay for their share
of new sewer infrastructure or improvements
necessitated by that development, as per the
current East Palo Alto fee schedule.

Goal ISF-4. Use best pracƟces to reduce
and manage solid waste.

Intent: To provide high-quality waste management
services to the community while reducing the negaƟve
health and environmental impacts of waste.

Policies:

4.1 Provide waste and recycling service. Provide solid
waste, recycling, and green waste services to the
community in compliance with State waste
diversion requirements, including Senate Bill 1383
organic waste mandates. If new funding sources are
idenƟfied, consider building recycling centers in the
city or partnering with Recology (or another service
provider) to provide addiƟonal recycling services.

4.2 Waste reducƟon. Seek to reduce East Palo Alto’s
rate of waste disposal per capita, and to increase
the diversion rate of recycling and green waste.

4.3 Zero waste government operaƟons. Work towards
zero waste government operaƟons, modeling best
pracƟces in solid waste management and recycling
for the rest of the community.

4.4 ConstrucƟon waste. Encourage all construcƟon
projects to divert 80 percent of their construcƟon
waste away from landfills, exceeding the CalGreen
requirement of a 65 percent minimum diversion
rate.

4.5 Hazardous waste disposal. Work with regional
agencies to educate residents about available dropoff and/or pickup points for e-waste and hazardous materials and chemicals such as paints, lubricants,
motor oil, pharmaceuƟcals, ferƟlizers, pesƟcides,
and other contaminants, to avoid their disposal into
the sewer and stormwater systems, waste streams,
or open space areas.

4.6 On-street recycling. Where feasible, provide
streetside recycling containers alongside public
trash receptacles.

4.7 Recycled building material. Encourage the use of
recycled building and infrastructure materials in
City operaƟons and construcƟon.

4.8 Paper waste reducƟon. Reduce paper waste and
encourage the use of recycled paper in City
operaƟons.

4.9 Packaging. Work with local food vendors and
farmer’s markets to promote the use of compost
friendly packaging.

4.10 Emergency SanitaƟon and Waste Management.

Coordinate with Recology and regional partners to
ensure conƟnued waste collecƟon, management of
contaminated materials, and provision of sanitary
faciliƟes during extended emergency events, with
priority for high-density and underserved
communiƟes.
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CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-12
Goal ISF-5. Fund construcƟon and
maintenance of basic infrastructure and
public faciliƟes.

Intent: Pursue public and private funding for construcƟon of infrastructure and public faciliƟes, with a goal of
addressing exisƟng deficiencies and miƟgaƟng the
addiƟonal impacts of new development.

Policies:

5.1 Impact fees. Collect nexus-based impact fees that
miƟgate the cost of providing infrastructure and
public faciliƟes to serve new development.

5.2 Community benefits. For large-scale projects,
negoƟate with developers to maximize the
potenƟal for acquiring community benefits like new
faciliƟes and infrastructure.

5.3 Grants and funding. Pursue grants and funding
sources that can be directed towards exisƟng
deficiencies in infrastructure and faciliƟes, including regular maintenance.

5.4 Special districts. As feasible, work with other
infrastructure providers (fire, water, sanitary) in
East Palo Alto to provide more effecƟve municipal
services through improved coordinaƟon or
consolidaƟon.

5.5 Priority Community Infrastructure Assessment.

Conduct comprehensive vulnerability assessments
of criƟcal infrastructure to idenƟfy flood risks,
structural deficiencies, and capacity limitaƟons,
with prioriƟzed investment in drainage
improvements, traffic safety infrastructure, and
emergency access routes, incorporaƟng current
and projected flooding condiƟons from sea level
rise and emergent groundwater.

Goal ISF-6. Ensure safe and wellmaintained telecommunicaƟons services.

Intent: To provide citywide access to telecommunicaƟons services for residents, students, and businesses, enabling successful business operaƟons and community
connecƟons within East Palo Alto and with the rest of the world.

Policies:

6.1 TelecommunicaƟons services. Work with uƟliƟes
and agencies to ensure high-quality citywide access
to telecommunicaƟons and energy services,
including backup power and communicaƟon
systems for criƟcal faciliƟes during emergency
events.

6.2 CollaboraƟon with Silicon Valley. Seek to establish relaƟonships and solicit funding or capital
investments from Silicon Valley technology
companies to expand affordable community access
to high-performing telecommunicaƟons and
technology, including Wi-Fi.

6.3 Wi-Fi hotspots. Encourage the commercial
marketplace to provide Wi-Fi hotspots throughout
the city.

6.4 Fiber opƟcs infrastructure. Require new
developments to install where feasible and ensure
compaƟbility with the most-up-to-date and
established broadband and telecommunicaƟons
technology.

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CHAPTER 9: INFRASTRUCTURE, SERVICES, AND FACILITIES
CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-13
Goal ISF-7. Ensure high-quality
educaƟonal opportuniƟes for East Palo
Alto students.

Intent: To invest in the educaƟon, personal beƩerment,
and long-term success of East Palo Alto’s children, young people, and adults, and aƩract and retain residents by
providing an excellent school system. To build and
coordinate systems of support so that the most vulnerable residents succeed from cradle to career, and have a clear path to the middle class.

Policies:

7.1 EducaƟonal quality. Collaborate with the
Ravenswood City School District, charter schools
and private schools to maximize educaƟonal
quality, maximize the use of exisƟng school sites for
educaƟonal purposes and improve the overall
quality of the schools and to ensure that East Palo
Alto residents are properly prepared for
employment and have the skills and educaƟon
levels needed to be compeƟƟve in current and
future job markets.

7.2 New programs. Encourage educaƟonal programs
from exisƟng educaƟonal providers in East Palo Alto
that improve the educaƟonal outcomes for East
Palo Alto residents.

7.3 EducaƟon hub. Support and enhance the emerging
educaƟon hub in Weeks near Myrtle Street and
Pulgas Avenue. Site new schools or charter
academies near exisƟng schools as opposed to
randomly throughout the city and encourage
nearby schools to share faciliƟes.

7.4 Student-community connecƟons. Encourage area
businesses, professionals, universiƟes, arƟsts, City
employees, or other community role models to
provide mentorship, job training, and/or financial
resources to local schools and students.

7.5 Early childhood educaƟon faciliƟes. Encourage
childcare faciliƟes in the city, including in public
buildings and major employment campuses, to
serve the needs of working families.

7.6 Cultural resources and faciliƟes. Preserve and
encourage faciliƟes, insƟtuƟons, buildings, and
organizaƟons that enhance cultural awareness and
educaƟon in East Palo Alto.

7.7 EducaƟon monitoring. Monitor the educaƟonal
aƩainment of East Palo Alto residents over Ɵme,
compared to residents of other jurisdicƟons in the
School District, and advocate for programs and
educaƟonal materials that are culturally sensiƟve
and allow East Palo Alto residents to improve their
educaƟonal aƩainment.

7.8 Adult educaƟon. Support the creaƟon of adult
educaƟon programs in East Palo Alto, including
English language classes, vocaƟonal training, and
on-going educaƟonal acƟviƟes.

7.9 AŌer school programs. Support aŌer school
programs that provide expanded educaƟonal
opportuniƟes and create a safe and affordable
place for youth aŌer school.

7.10 Libraries. Coordinate with San Mateo County to
provide library services for the community, aiming
to provide approximately 750 square feet of
equipped and staffed library space per 1,000
residents.

7.11 School Climate Resilience. Collaborate with
Ravenswood City School District and charter school
operators to ensure school faciliƟes are resilient to
climate hazards, including extreme heat, flooding,
and severe weather, and are equipped to serve as
community resilience centers during emergencies
when appropriately prepared.

225
CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-14
Goal ISF-8. Provide high-quality public
and civic faciliƟes for the community.

Intent: To provide the physical buildings, venues, and other faciliƟes necessary to conduct civic acƟviƟes and City
business, while fostering community cohesion, vibrancy, and character.

Policies:

8.1 New City Hall and civic district. Develop a civic
district to house City Hall and other City offices and
faciliƟes, providing a beauƟful, publicly- accessible
seƫng for civic life in East Palo Alto.

8.2 Community center on Westside. Strive to locate a
new community center on the Westside to serve
the populaƟon in this area.

8.3 Community meeƟng faciliƟes. Take steps to
expand the number and diversity of community
meeƟng faciliƟes, encouraging new development to
construct such spaces as part of development
projects.

8.4 Community center and faciliƟes standards. Strive
to provide 2,000 square feet of publicly accessible
community center space or community meeƟng
space per 1,000 residents, either in a City facility or in coordinaƟon with other partners.

8.5 Civic and insƟtuƟonal uses. Locate civic and
insƟtuƟonal uses in central, walkable, and transitserved locaƟons.

8.6 Role of civic buildings. Require civic buildings to be disƟncƟve, beauƟful, and architecturally beneficial
to the fabric of the city.

8.7 Family-friendly gathering spaces and businesses.

Encourage safe and family-friendly public gathering
spaces and private businesses such as community
centers, movie theaters, entertainment center, and
other uses focused on youth and families to locate
in the city.

8.8 Equitable distribuƟon of faciliƟes and services.

Strive to equitably distribute public faciliƟes,
improvements, and services throughout East Palo
Alto, with priority given to remedying exisƟng
deficiencies in underserved areas of the city.

Goal ISF-9. Maintain and pursue
services, programming, and humane
social policies to serve the community
and improve quality of life.

Intent: To foster community cohesion, vibrancy, and social connecƟon. To provide comprehensive, integrated social
services to vulnerable children and families. To recognize that families seeking assistance oŌen face mulƟple,
complex needs and that they typically require the services of more than one program.

Policies:

9.1 CoordinaƟon to provide services. Work closely
with local agencies and services providers to
provide and coordinate social services.

9.2 Customer service. Strive for a high level of
customer service and accessibility to the
community on the part of the City government.

9.3 Support community fesƟvals and programming.

Maintain and support exisƟng community fesƟvals
while seeking new opportuniƟes to hold
community events, encourage social gathering, and
program public space.

9.4 Equitable distribuƟon of services. Ensure that Citysponsored social service programs are provided for all racial and ethnic groups in the city.

9.5 AlleviaƟng homelessness. Work with local service
providers and agencies to alleviate homelessness
and ensure services are available for those
experiencing temporary or long-term
homelessness.
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CHAPTER 9: INFRASTRUCTURE, SERVICES, AND FACILITIES
CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-15

9.6 Low-income residents and families. Work with
low-income families and residents to access various
forms of assistance, access to jobs, social services,
childcare services, and other assistance for those in
need.

9.7 Regular analysis of staffing levels. Regularly study staffing needs to ensure East Palo Alto is providing
compeƟƟve levels of service and meeƟng resident
and business expectaƟons.

9.8 Funding. Seek funding for social service programs
from county, State, and federal sources.

Goal ISF-10. Provide excellent
emergency services to the community.

Intent: To increase safety, health, peace of mind, and
quality of life through excellent police, fire, and EMS services, as well as emergency preparedness for natural disasters.

Policies:

10.1 Crime-prevenƟon through Environmental Design
(CPTED). Work with the police and planning
departments to deter crime by encouraging CPTED
strategies in new and exisƟng development,
including the following strategies:
• AcƟve public space.
• Building design to promote “eyes on the
street”.
• Clear delineaƟon between private and public
space.
• Natural access control between public and
private space.
• Maintenance of public places.
• Removal or repair of vandalism or broken
property.

10.2 Emergency preparedness. Work with MPFPD,
EPAPD, City staff, and East Palo Alto residents to
ensure that sufficient emergency plans and
resources are established and known by all
stakeholders. Ensure that all City employees
partake in yearly emergency drills and/or trainings.

10.3 Fire and emergency services. ConƟnue to
coordinate with the Menlo Park Fire ProtecƟon
District (MPFPD) to ensure excellent fire and
emergency services.

10.4 Excellent police service. Strive to conƟnuously
improve the performance and efficiency of the East
Palo Alto Police Department.

10.5 Police-community relaƟons. ConƟnue to foster
posiƟve, peaceful, mutually supporƟve
relaƟonships between East Palo Alto residents and
the police. Promote addiƟonal visibility of police
throughout residenƟal neighborhoods.

10.6 Data-driven policing. Monitor crime data and
ensure sufficient crime prevenƟon resources are
deployed at effecƟve Ɵmes in areas with criminal
acƟvity.

10.7 Code enforcement. Work to ensure that buildings,
homes, yards, businesses, and public spaces are
free from hazards. Maintain cooperaƟon and
communicaƟon between the Code Enforcement
Division (within EPAPD), the Planning Division, and
the Building Department on issues relaƟng to
neighborhood quality of life.

10.8 Community reentry. Encourage and support efforts
that foster an inclusive community and help
reintegrate formerly incarcerated persons into
posiƟons of employment and posiƟve roles in the
community (including working with local
employers).

10.9 Policy refinement. Engage residents and businesses in processes to evaluate, refine, and establish laws
that enhance public safety and quality of life.
227
CITY OF EAST PALO ALTO: GENERAL PLAN 2035 | 9-16

10.10 Emergency Infrastructure Resilience. Coordinate
with uƟlity and service providers to ensure that
criƟcal infrastructure, including potable water
access, sanitaƟon systems, and communicaƟon
networks remain funcƟonal during and aŌer
emergency events, with conƟngency plans for
infrastructure failures.
228
229
230
Dear Mayor and Members of the City Council,
Nuestra Casa is pleased to submit comments on the draft Infrastructure, Services, and Facilities Element of the East Palo Alto General Plan. Nuestra Casa has been supporting families for more than 20 years in accessing critical services and nurturing their inherent leadership so that their voices are reflected in decision-making. Nuestra Casa has been working on water justice since 2019. We’ve been educating the community of East Palo Alto on their drinking water and providing support in their goals of water affordability and improving water quality through infrastructure updates. This letter is written with the thoughts and concerns we’ve been hearing from our community.

We thank and recognize the City’s initiative in drafting an updated Infrastructure, Services, and Facilities Element, which comprehensively regards community concerns and equity-based strategies. In particular, we appreciate the inclusion of Goal ISF-2, especially policies 2.1, 2.2, and

2.11. We offer the following recommendations to strengthen the strategies and accountability of Goal ISF-2 within the element:

1. Strengthen community trust and education by expanding beyond water conservation.

We commend the inclusion of policy 2.11, which has the goal of educating the public on water conservation. However, we believe that public education should also include a focus on increasing the understanding and trust of the water system. Through our experience, trust is important if you want to foster support for the water system and translate the successes to the community. Without trust in their water system, people will remain skeptical of their tap water quality even if the city is spending a lot of energy on improving the system. Policies on public education should ensure that outreach is done on drinking water sources, water monitoring methods, and decision-making structures. Additionally, public education should be delivered in a culturally relevant manner, with multilingual resources and in partnership with community-based organizations. We also highlight Nuestra Casa as a potential partner in this effort, drawing on our water workshop earlier this year, where more than 40 community members attended to learn about their water. During the February workshop, the utility manager for East Palo Alto was also present, reinforcing the value of collaboration between the city and community organizations. We believe a continued partnership with the city would further support the goals of policy 2.11. We’d also like to reference Valley Water and its robust water education program as strong examples of what water education can look like.

2. Proactively pursue funding for water supply infrastructure and the distribution network.

Given the scale of infrastructure needs—particularly for the water supply as outlined in policy

2.2—the draft Element should include policies that direct staff to actively pursue external funding opportunities. This includes state funding sources such as the Climate Bond, SAFER, and the Drinking Water State Revolving Fund. Proactive funding strategies will be essential to improving the water infrastructure. We’d also like to highlight the need for infrastructure improvements to the 231
distribution network. The distribution network is an essential piece that ensures the delivery of quality water to our residents, and is the infrastructure most residents would want to see improvements in. Nuestra Casa is open to collaborating with the city on funding opportunities to develop community-centered applications that draw on our deep trust with residents to put forward strong, compelling proposals.

3. Increase awareness of water planning documents
Given Policy 2.1’s commitment to maintaining key water planning documents, there should be a strategy to improve community understanding and input for the Water System Master Plan. This document is central to how the City manages water supply and infrastructure, yet it can be difficult for the public to access and interpret. Developing outreach strategies, such as dedicated public sessions to explain the Water System Master plan, along with regular updates on its implementation, would make this information more accessible, increase public understanding, and advance the goals of Policy 2.11. A great example of this is in the East Palo Alto Park’s master plan, which partnered with Nuestra Casa and other community organizations to conduct surveys and focus groups.

4. Establish near-term and long-term implementation actions.

To support timely progress, policies should be accompanied by clearly defined implementation timeframes. Distinguishing between short-term (0–3 years) and long-term (3+ years) actions will help prioritize investments, align with capital investment cycles, and provide transparency to the community. See the City of Oakland’s 2023 Safety Element update, page 5-1.

5. Provide annual public reporting on progress.

To ensure transparency and maintain momentum, we recommend that the City commit to an annual progress report on Infrastructure, Services, and Facilities Element implementation. This report should be presented to the City Council and made publicly available on the City’s website. The report should include clear benchmarks, measure progress toward goals, and highlight the remaining gaps. Regular updates will help track accomplishments, identify gaps, and build community trust.

Overall, we strongly support the City’s efforts on this Element update. With clearer implementation mechanisms and accountability measures, this document can serve as a powerful tool to guide investments and protect the community in the years ahead.

Thank you for your leadership and consideration,
Miriam Yupanqui
Executive Director
232
April 23, 2026
Subject: PACT Public Comment on City of East Palo Alto Draft Safety Element Dear Mayor and Members of the City Council,
The Peninsula Accountability for Contamination Team (PACT) is pleased to submit comments on the draft Safety Element of the East Palo Alto General Plan. PACT’s mission is to advocate alongside community members to advance contaminated site clean-up and infrastructure resilience, in the face of present and future sea level and groundwater rise risks in low-lying areas of the Peninsula and beyond. Through this work, PACT aims to safeguard the health and well-being of our community for generations to come.

We appreciate the City’s leadership in advancing a comprehensive Safety Element update that addresses climate-driven hazards and prioritizes community safety and equity. We offer the following recommendations to strengthen implementation and accountability of the Element:

1. Strengthen accountability through clear implementation responsibility.

While the draft includes strong and thoughtful hazard mitigation and community safety policies, their effectiveness depends on clear lines of accountability and responsibility for implementation.

We recommend identifying the lead and supporting departments (e.g., Public Works, Planning, etc.) responsible for implementing each policy. This will improve coordination and drive outcomes. See the City of Oakland’s 2023 Safety Element update, page 5-1.

2. Establish near-term and long-term implementation actions.

To support timely progress, policies should be accompanied by clearly defined implementation timeframes. Distinguishing between short-term (0–3 years), medium term (3-5 years),and long-term (5- 8 years) actions will help prioritize investments, align with capital investment cycles, and provide transparency to the community. See the City of Oakland’s 2023 Safety Element update, page 5-1.

3. Establish consistent, enforceable flood and sea level rise design standards to operationalize the Safety Element’s policies.

City-wide, enforceable development standards that account for both current and future flood and contamination risks will make the Safety Element policies actionable and predictable, reduce long-term risk, and help ensure that projects are permittable and resilient over time. Enforceable development standards should include: harmonizing citywide floodplain/sea level rise standards with the stronger 2024 RBD Specific Plan design-flood-elevation and shallow groundwater assessment requirements; standardize submittal checklists so development review consistently captures buoyancy, corrosion, infiltration, and contaminant mobilization risks identified in SN-5.2 233
and SN-5.4. Operationalize SN-12.5 (prohibition on new hazardous-material facilities in emergent groundwater areas) through business licensing and land-use permitting screens. Please take a look at Save the Bay’s East Palo Alto Flood Resilience Snapshot for more ideas.

4. Proactively pursue funding for priority resilience investments.

Given the scale of infrastructure needs—particularly for stormwater management and flood protection—the draft Safety Element should include policies that direct staff to actively pursue external funding opportunities. This includes state funding sources such as the Climate Bond, federal funding, and other resilience-focused grants. Proactive funding strategies will be essential to advance critical projects that reduce flood risk and protect vulnerable neighborhoods. PACT would like to offer our support in developing robust and community-informed funding applications.

5. Provide annual public reporting on progress.

To ensure transparency and maintain momentum, we recommend that the City commit to an annual progress report on Safety Element implementation. This report should be presented to the City Council and made publicly available on the City’s website. Regular updates will help track accomplishments, identify gaps, and build community trust.

Overall, we strongly support the City’s efforts on this Safety Element update. With clearer implementation mechanisms and accountability measures, this document can serve as a powerful tool to guide investments and protect the community in the years ahead.

In addition to our high-level recommendations, please consider our following recommendations on strengthening specific policies in the Flooding, Sea Level Rise, Groundwater Rise, and Hazardous Materials sections of the draft Safety Element.

Policy Comment
Seismic & Soil-Related Hazards
Liquefaction description (p 10-10) Studies from USGS have linked sea level and groundwater rise to increased liquefaction
risks - this should be noted in the document.

See here for more information.

We suggest also providing a more explanatory
description of how liquefaction impacts homes,
other buildings, and infrastructure. Provide an
example from past earthquakes, such as when
homes in the SF Marina District experienced
differential settlement and collapse in the 1989
Loma Prieta earthquake. This will make it
clearer what the hazard is.
234

2.4 Site-Specific Geotechnical Investigations
Require individual site-specific geotechnical
investigations for new construction and
substantial improvement projects within
liquefaction hazard zones and tsunami-prone
areas, as shown on Figures 10-3 and 10-4, to
determine the depth of bedrock, soil stability,
location of rift zones, and other localized
geotechnical problems as part of the
environmental and/or development review
process for all structures.

To reflect policies in the emergent groundwater
section, we suggest adding a note about
including sea level rise and groundwater rise
into these site-specific geotechnical
investigations.

Flooding
Stormwater flooding definition (p 10-14) Stormwater flooding occurs when rainfall accumulates in areas with insufficient drainage
throughout the community, especially in the
Gardens neighborhood, and during episodes of
high tides when the city’s shallow groundwater
table is highest.

Major sources of flooding in East Palo Alto: high
tides, heavy rains, and an inadequate storm
drain system (p 10-14, 10-17)
Policy 3.11 Drainage Improvements
Policy 3.12 Storm Drain System Upgrades
As the “inadequate storm drain system” is the
only thing that the city has control over in this
list of flooding sources, and the storm drain
system doesn’t, presently, adequately handle
10-year storm events as it should (at a
minimum), and the city identifies that the
Storm Drain Master Plan will cost nearly $40
million to implement – the city must state
that one policy/action must be to seek and
secure funding from the state or federal
government to advance these critical
upgrades to protect the community from
flood risk. How is the city planning to pay for
these upgrades, and what is the timeline? This
information should be included in the Safety
Element update.

Policy 3.11 Drainage Improvements
IM 3.11a: Establish regular maintenance
schedules for City storm drain infrastructure.

Timeframe: Short-Term
Establish regular maintenance schedules for
City storm drain infrastructure with designated
staffing and appropriate city budget.

Goal SN-3. Provide adequate flood control
and storm drainage facilities to minimize
Many of the policies outlined under Goal SN-3
could be met through the implementation of
235
the risk of flooding.

Intent: To lessen the impacts of flood events on
City residents by avoiding placing residents in
harm’s way.

Shallow Groundwater and Sea Level Rise
Overlay Districts in the city. Overlay Districts
are a land use tool that creates specific design
and retrofit requirements for underground
infrastructure, roadways, and new
development in specific areas - in this case,
areas at risk of sea level rise, groundwater rise,
and storm flooding.

3.10 Drainage and Flood Control Systems.

Design and implement integrated stormwater
management systems that combine traditional
drainage infrastructure with green
infrastructure elements (such as bioswales,
rain gardens, and permeable surfaces) to
improve flood control while enhancing local
ecosystems.

We recommend exploring more substantial
stormwater systems to complement the green
infrastructure already mentioned. Additional
large holding ponds, such as the one near the
O'Connor Pump Station along with retention
basins distributed throughout the city,
represent critical engineered infrastructure
that would provide more controlled flood
protection for the community. These systems
require architects and hydrologists to analyze
site-specific hydrology, soil properties, and
downstream impacts to ensure they do not
overwhelm existing infrastructure.

We also recommend developing a community
outreach plan around bioswale installations,
particularly where parking elimination is
required. Parking loss is a significant concern
for residents, so identifying opportunities to
offset that loss with additional parking nearby
will be important to community acceptance.

Sharing a clear plan with residents ahead of
any streetscape changes one that highlights the
reasoning behind these decisions and the
long-term flood protection benefits will help
build understanding and trust in these
improvements.

Sea level rise
Goal SN-4. Protect the community from sea
level rise impacts through adaptive
planning, regional coordination, and
resilient infrastructure development.

Intent: To reduce risks from permanent and
temporary inundation due to sea level rise and
ensure that planning and development decisions
We recommend breaking this goal into two
parts, one goal to address short-term impacts
of sea level rise and one to address longer term
impacts
236
account for projected future conditions over the
life of projects.

Emergent Groundwater

5.2 Development Requirements in Emergent
Groundwater Areas.

5.4 Geotechnical Assessment and Mitigation for
Emergent Groundwater Areas.

Clarify the difference between these two
policies - one seems to say “encourage…
geotechnical investigations,” the other says
“require…geotechnical investigations”. We
would like these geotechnical investigations in
current emergent groundwater areas, as well as
in areas where groundwater is “very shallow”
or within 3.3 feet of the surface (in Figure 10-9)
to be required for new construction and major
redevelopment, and for mitigation solutions to
be developed. We suggest that the city establish
measurable triggers for action, such as when
groundwater depth reaches a certain level,
flood event frequency, etc.

Contaminated Site Cleanup in Emergent
Groundwater Areas. Proactively coordinate
with the San Mateo County Certified Unified
Program Agency (CUPA), California Department
of Toxic Substances Control, and State Water
Resources Control Board to prioritize the
cleanup and remediation of contaminated sites
located in areas vulnerable to emergent
groundwater, as shown on Figure 10-9 and
Figure 10-9, where rising groundwater
threatens to mobilize contaminants, with
particular emphasis on protecting
environmental justice communities and
residential neighborhoods.

We support the city's commitment to
proactively coordinating with CUPA, the
Department of Toxic Substances Control, and
the State Water Resources Control Board on
contaminated site cleanup in emergent
groundwater areas. To strengthen this policy,
we recommend the following addition:

Require vapor intrusion screening for sensitive
uses including housing, schools, and childcare
facilities both on and near affected sites, with a
clear preference for full cleanup over long-term
exposure management strategies that leave
residents bearing ongoing risk. This is
especially critical in environmental justice
communities and residential neighborhoods,
where residents are most vulnerable to
cumulative health impacts and least able to
absorb the consequences of delayed or
incomplete remediation.

Hazardous Materials

12.7 Mitigate Hazardous Material Risks
from Groundwater. Require existing facilities
Require existing facilities in emergent
groundwater areas that handle hazardous
237
in emergent groundwater areas that handle
hazardous materials to implement
comprehensive monitoring, containment, and
emergency response measures to prevent
contamination from groundwater intrusion.

Establish requirements for relocating or
decommissioning highest-risk facilities based
on vulnerability assessments.
materials to implement comprehensive
monitoring, containment, and emergency
response measures to prevent contamination
from groundwater intrusion. Require that
contamination investigation and cleanup plans
be reviewed and approved before any grading
or earthwork begins. Establish requirements
for relocating or decommissioning highest-risk
facilities based on vulnerability assessments.

Develop a long-term monitoring plan for sites
where full remediation has not been achieved,
committing to best available science and
methods to detect and respond to contaminant
remobilization over time.

Thank you for your leadership and consideration.

Sincerely,
Jennifer Adams
Environmental Justice Program Director at Nuestra Casa
Adriana Fernandez Arriaga
Public Policy Manager at El Concilio of San Mateo County Cade Cannedy
Sr. Director of Programs and Communications
Sarah Atkinson
Hazard Resilience Sr. Policy Manager at SPUR
Pam D Jones
Program Manager, Belle Haven Empowered
Filiberto Zaragoza
Campaign Organizer, Youth United for Community Action
238
April 24, 2026
Elena Lee, Planning Division Manager [ [email protected] ] City of East Palo Alto
cc:

City Council
Planning Commission
Subject: Technical Recommendations to Strengthen the Safety Element for Effective, Citywide Implementation
Dear Ms Lee,
The Loma Prieta Chapter of the Sierra Club, Green Foothills and Citizens Committee to Complete the Refuge respectfully submit the following comments on East Palo Alto’s draft Safety Element Update. Our organizations collectively represent thousands of members in and around East Palo Alto and have a deep interest in the San Francisco Bay, its ecosystems, and the surrounding shoreline communities where development and planning decisions have long-term consequences for public health, climate resilience, and environmental justice.

The draft Safety Element provides a strong and thoughtful assessment of the risks facing East Palo Alto, particularly related to flooding, sea level rise, groundwater rise, and contamination. We appreciate the City’s leadership in identifying these complex and interconnected challenges.

However, while the draft effectively identifies risks, it does not yet consistently translate those risks into a clear, enforceable policy framework. To ensure the Safety Element functions as an effective tool for protecting the East Palo Alto community, we recommend strengthening the plan by establishing explicit requirements, clear triggers for action, and a cohesive, citywide approach. The comments below are intended to support that next step.

1. Establish Comprehensive Flood and Sea Level Rise Development Standards The Safety Element identifies significant and increasing flood risk, including limitations in existing stormwater infrastructure and the growing impact of emergent groundwater. However, the current draft policies place primary emphasis on floodplain management and building elevation. This approach does not fully address the movement of water across sites, 1 239
infrastructure systems, and neighborhoods under future conditions, including compound flooding dynamics, particularly in a low-lying area with known drainage constraints and reliance on pumping systems.

We appreciate that IM 3.4a would require new development to provide replacement flood storage capacity to ensure no net loss. In addition, Policy 3.10 calls for integrating traditional drainage infrastructure with green infrastructure elements, and IM 3.11a promotes the use of permeable surfaces. However, these latter provisions remain high-level and discretionary and do not yet establish specific, enforceable, and predictable design requirements.

We recommend consolidating and strengthening these provisions into a comprehensive framework of development standards and site-level design requirements to ensure coordinated and reliable management of flood and stormwater conditions at the building, site, and system level. This framework should coordinate screening criteria, site-level analysis, and integrated development standards so that potential risks are identified early, evaluated consistently, and addressed through effective design responses.

See Section 6.1 for proposed policy language and insertion points.

2. Establish Quantifiable Triggers for Groundwater and Flood Risk The draft Safety Element appropriately identifies emergent groundwater as a widespread and growing hazard and includes important requirements in Policy 5.4 for geotechnical investigation and mitigation within mapped emergent groundwater risk areas. This provides a strong foundation for addressing groundwater-related risks.

However, the current framework relies primarily on mapped conditions tied to specific sea level rise scenarios, and Policy 5.2 continues to frame investigation as discretionary in areas “at risk.” Together, these provisions leave considerable uncertainty about what is required as groundwater conditions evolve. As a result, the policies do not yet provide a clearly defined pathway for
● determining when site-specific investigation is required, and ● translating investigation results into consistent mitigation and monitoring responses.

We recommend strengthening and clarifying these provisions by establishing a more explicit framework that incorporates screening criteria, site-specific analysis, and measurable thresholds to ensure timely and predictable application of investigation, mitigation, and monitoring requirements over time.

See Section 6.2 for proposed policy language and insertion points. 2 240

3. Strengthen Contamination and Public Health Protections The draft Safety Element recognizes that rising groundwater may mobilize contamination and expand exposure pathways across the city. This is a significant public health concern, particularly given the extent of legacy contamination in areas vulnerable to groundwater rise.

However, current policies do not consistently translate this risk into clear, enforceable requirements for development review, particularly with respect to when investigation is required and how risks must be addressed.

We recommend establishing a framework for contamination risk management that incorporates triggers for investigation, defined mitigation requirements, and standardized monitoring approaches to ensure effective protection of public health, particularly in areas where groundwater rise may influence contaminant movement.

See Section 6.3 for proposed policy language and insertion points.

4. Address Emerging Risks from Life Sciences and Research Uses The draft Safety Element addresses hazardous materials broadly but does not yet account for the increasing presence of life sciences and laboratory uses in the region, which introduce distinct safety considerations, including biological hazards, specialized waste streams, and emergency response requirements.

Other jurisdictions have begun to adopt enforceable standards to manage these risks. For example, San Carlos prohibits projects with biosafety level designations BSL-3 and BSL-4. 1 Redwood City adopted detailed standards for research and development, laboratory uses. 2 Without clear standards, East Palo Alto may face gaps in public health protection and land use compatibility, particularly near sensitive receptors such as homes, schools, childcare facilities, and wildlife habitat.

We recommend establishing specific requirements governing biosafety levels, land use compatibility, and required safety planning to ensure the safe siting and operation of laboratory and research uses.
2 Redwood City Downtown Precise Plan, DTTP-Wide Amendments, Approved June 26, 2023, Sec. 2.2.4. https://webapps.redwoodcity.org/files/cd/Gatekeeper/Combined-Text-Maps-and-Charts-Updated-for-TD. pdf
1 Curry, R. (2023, June 28) San Carlos votes to ban high-risk bio labs that study HIV, COVID-19, smallpox and other viruses, ABC 7 News
https://abc7news.com/post/san-carlos-bio-labs-health-risk-banning-high/13437843/?userab=abcn_du_ca t_topic_feature_holdout-474*variant_b_redesign-1939%2Cotv_web_content_rec-539*variant_c_trending-2 268%2Cotv_search_page_design_unification-546*variant_b_search_redesign-2300%2Cabcn_popular_read s_exp-542*variant_b_7days_filter-2288
3 241
See Section 6.4 for proposed policy language and insertion points.

5. Establish a Unified, Citywide Framework for Implementation Many strong development and safety standards already exist within City plans, including the 2024 Ravenswood/4 Corners Specific Plan Update, but they are not consistently applied across the city. This fragmented approach can result in uneven implementation and reduced effectiveness in achieving the Safety Element goals. The 2024 Ravenswood/4 Corners Specific Plan includes detailed, risk-responsive standards; this update presents an opportunity to extend those approaches into a consistent, citywide framework.

We recommend integrating these standards into a coordinated citywide approach within the Safety Element, with consistent triggers and enforcement mechanisms to ensure reliable applicability across all development and planning contexts.

See Section 6.5 for proposed policy language and insertion points.

6. Detailed Policy Recommendations and Suggested Insertion Points The following language is intended to align with the City’s existing Safety Element structure and can be adapted as needed.

6.1 Flood and Sea Level Rise Development Standards
Goal SN-3 (Flooding) and Goal SN-4 (Sea Level Rise)
Add New Policy
Policy 3.X Integrated Flood-Resilient Development Standards. Require new development and substantial improvements to incorporate integrated flood and sea level rise resilience measures that address building elevation, site design, and stormwater management based on projected future conditions.

Add New Implementation Measure
IM 3.X Flood-Resilient Development Standards. Develop and adopt citywide development standards for flood and sea level rise resilience. These standards shall, at a minimum ● Require minimum finished-floor elevations tied to the City’s Design Flood Elevation (DFE) ● Require on-site stormwater detention and retention sized for projected future conditions ● Require use of permeable surfaces where feasible
● Require incorporation of green infrastructure features (e.g., bioswales, rain gardens) ● Require evaluation of compound flooding risks, including interaction with groundwater rise
● Require site-level hydrologic analysis for projects subject to elevated flood or groundwater risk, as identified through screening criteria or applicable hazard maps, and 4 242
use this analysis to inform application of DFE, stormwater sizing, and site design requirements.

These requirements shall be applied collectively to ensure integrated site performance under future flood conditions.

Conforming Edits
Policy 4.7: Revise to reference DFE and integrated development standards Policy 3.10: Revise to align stormwater requirements with these standards

6.2 Groundwater and Flood Risk Triggers
Goal SN-5 (Emergent Groundwater)
Revise Policy 5.2
Replace “encourage” with “require” for geotechnical and hydrological investigations.

Revise Policy 5.4
Add: “…and in areas where latest available data indicates potential for shallow groundwater conditions…” following the reference to Figures 10-9 and 10-10.

Add New Policy
Policy 5.X Groundwater Risk Assessment and Response. Establish a consistent framework for groundwater risk management that includes screening criteria to determine when geotechnical and hydrologic investigation is required and defined thresholds to guide mitigation and monitoring based on investigation findings.

Add New Implementation Measure
IM 5.X Groundwater and Flood Risk Screening and Response. Develop and apply screening criteria and thresholds for groundwater and related flood risk. This shall include the following:
● Screening criteria based on mapped groundwater areas, topography, proximity to shoreline or creeks, drainage constraints, and available data ● Requirement for geotechnical and hydrologic analysis when screening criteria are met ● Defined thresholds to guide structural design, monitoring, and contamination risk management
● Evaluation under current and projected future conditions ● Use of analysis results to inform flood-resilient development standards, including DFE application and site design requirements, and
● Integration into development review and permitting processes

6.3 Contamination and Public Health Protection
Hazardous Materials Section
Add New Policy
5 243
Policy X Contamination Risk Assessment and Response. Require a coordinated approach to contamination risk management that incorporates screening criteria, site-specific investigation, and appropriate mitigation and monitoring requirements, including consideration of changing groundwater conditions.

Add New Implementation Measure
IM X Contamination Risk Management Standards and Program. Develop and implement citywide standards and procedures to identify, assess, and manage contamination risks associated with development, particularly in areas affected by groundwater rise and legacy contamination. This program shall incorporate the following.
● Establish screening criteria to identify sites requiring contamination assessment, including sites with known or suspected contamination, proximity to hazardous uses, and areas vulnerable to groundwater rise.
● Require site-specific investigation and risk assessment for sites meeting screening criteria, including evaluation of exposure pathways such as vapor intrusion, consistent with applicable regulatory agency requirements.
● Require remediation or risk management plans to be approved prior to grading or earthwork, with sequencing of cleanup prior to development. ● Address potential interactions between groundwater rise and contaminant behavior, using best available data and coordination with relevant regulatory agencies. ● Establish monitoring, reporting, and long-term management requirements, as appropriate.
● Build on the draft Safety Element’s contaminated-site database and multilingual outreach commitments by providing a publicly accessible tracking tool that supports transparency and accountability. This tool should
● map contaminated sites and areas vulnerable to groundwater rise, ● identify priority sites for investigation and cleanup based on exposure risk, proximity to sensitive uses, and environmental justice considerations, ● track remediation or risk management status and timelines, as available, and ● identify responsible departments and points of contact.

These standards should align with and build upon the contamination management approaches adopted in the Ravenswood/4 Corners Specific Plan, including policies under Goals LU-4 and LU-5.

6.4 Life Sciences and Laboratory Safety
Hazardous Materials Section (new subsection)
Add New Goal
Goal SN-X Biosafety. Ensure safe siting and operation of laboratory and research uses.

Add Policy
6 244
Policy SN-X Laboratory Safety Standards and Review Procedures. Develop and implement standards and review procedures for laboratory and research uses to ensure safe siting, design, and operation.

Add Implementation Measures
IM SN-X.1 Limit laboratory uses to BSL-1 and BSL-2; prohibit BSL-3 and BSL-4.

Alternate IM SN.1 (if the City allows BSL-3 and BSL-4 uses): Establish a full Environmental Impact Report as the default level of review for any project involving businesses that use hazardous chemicals or perform biological research classified as BSL-3 or BSL-4. 3 IM-SN-X.2 Establish laboratory and research use standards. This program shall ● establish standards for land use compatibility, including proximity to or co-location with sensitive receptors,
● require project-specific safety planning, including biosafety, emergency response, and hazardous materials management plans, as appropriate.
● require coordination with relevant regulatory agencies, including Fire, CUPA, and applicable state and federal authorities, and
● establish operational and design requirements to ensure safe handling, storage, and containment of hazardous materials.

6.5 Citywide Standards Integration
Add New Policy
Policy SN-X Citywide Standards Integration. Establish a coordinated, citywide approach to applying development and safety standards across plans, policies, and implementation tools.

Add New Implementation Measure
IM SN-X Standards Integration Program. Develop and implement a program to align and apply development and safety standards consistently across City plans and regulatory processes.

This program shall include the following:
● Conduct a review and comparison of existing City plans, including the Ravenswood/4 Corners Specific Plan, to identify and align applicable standards and approaches. ● Incorporate relevant and effective standards into the Safety Element and related implementation tools.
● Ensure alignment with zoning, building code, and development review processes. 3 Under the terms of the settlement agreement between Menlo Park and East Palo Alto, as stated in the Draft EIR for 1005 O’Brien and 1320 Willow Road “...East Palo Alto will prepare an Initial Study for future development projects in that city to determine the appropriate level of environmental review and will conduct that review, which can be simplified by incorporating by reference analysis and discussions from its general plan, referred to as Vista 2035.” If BSL-3 or BSL-4 projects are allowed, Alternate IM SN-X.1 establishes an EIR as the default level of environmental review. This Safety Element approach is consistent with the settlement agreement and would provide essential analysis and transparency about risks to the community from the introduction of these more hazardous materials. 7 245
● Establish consistent triggers, requirements, and review procedures across hazard types, including flooding, groundwater rise, and contamination. ● Provide guidance to staff and applicants to support consistent application during project review.

Conclusion
The draft Safety Element provides a strong analytical foundation. With the additions outlined above, it can more effectively serve as a clear, enforceable, and citywide framework that protects public health, reduces risk, and advances equitable outcomes.

We appreciate your consideration and look forward to continued engagement.

Sincerely,
Jennifer Hetterly
Campaign Coordinator
Sierra Club Loma Prieta Chapter Bay Alive Campaign
Alexandra Mendoza
Environmental Associate
Green Foothills
Eileen McLaughlin
Board Member
Citizens Committee to Complete the Refuge
8 246
April 24, 2026
Re: Comments on the East Palo Alto Draft Safety Element Update Dear Safety Element Update Team,
Thank you for the opportunity to provide comment on the East Palo Alto Safety Element update. Save The Bay works across the Bay Area region to advocate for smart climate resilience policies. We hope for a Bay Area where homes and infrastructure are protected from flooding, where nature-based solutions are prioritized, and where frontline communities are partners in climate solutions.

We appreciate the city’s outreach and engagement efforts in drafting the Safety Element and its multijurisdictional collaboration through PrepSMC. We are very glad to see that the draft makes strong commitments to adopting flood resilience standards for developments in the sea level rise zone, addressing groundwater rise and the associated risk to contaminated sites, and utilizing nature-based solutions and green infrastructure for flood resilience.

We especially support the following policies that were included in the draft Safety Element, and we hope to collaborate with the City in implementing these policies:
• Policy 3.9: Partnering with community-based organizations to provide resources to lowresourced households to harden their homes against flooding and investigating a residential flood retrofit grant program.
• Policies 4.1, 4.7, & 5.2: Applying flood control and mitigation requirements to properties vulnerable to sea level rise and groundwater rise. Requiring new development in the sea level rise and groundwater rise zone to elevate habitable areas above projected sea level rise elevations and to assess the project’s vulnerability to groundwater rise. o We recommend implementing this policy by following OneShoreline’s Policy Planning Guidance for creating sea level rise and groundwater rise overlay zones. It provides template language for incorporating flood resilience standards into the zoning code. • Policy 4.3: Siting new critical infrastructure outside of the sea level rise hazard zone when possible or ensuring that facilities are constructed to be flood resilient. • Policy 4.4 & 5.1: Integrating sea level rise and groundwater rise considerations into all Capital Improvement Projects.
o We recommend that the city implement this through creating sea level rise resilience guidelines that all Capital Improvement Projects in the sea level rise zone should adhere to. An example of this is San Francisco’s Sea Level Rise Checklist for capital projects. • Policies 5.5 & 12.1: Proactively coordinating with oversite agencies to prioritize the cleanup and remediation of contaminated sites located in areas vulnerable to emergent groundwater with an emphasis on environmental justice communities. Maintaining an updated database of contaminated sites and holding public, multilingual workshops with community mebmers. 247
o Many local community-based organizations such as YUCA, Nuestra Casa, and Climate Resilient Communities (CRC) have been doing community work to help residents understand these risks and advocate for their health. We recommend working closely with these organizations in implementing these policies.

We encourage the team to include the following additional policies in the final Safety Element to strengthen the city's understanding of compounding flood risks and enhance green stormwater infrastructure in the city.
• Under Goal SN-3, add policy: Conduct a study to map areas projected to flood under future climate change-driven rainfall conditions. Model how future rainfall will interact with rising sea levels and groundwater levels and use this data to inform the Storm Drain Master Plan and shoreline flood protection projects.
• Under Goal SN-3, add policy: Implement a Green Stormwater Infrastructure (GSI) checklist for capital projects to ensure there are no missed opportunities for incorporating GSI into new projects. Design and site GSI projects for multiple benefits including flood resilience, urban heat reduction, pollution prevention, and community enhancement. • Under Goal SN-4, add policy: Require disclosure of sea level rise and other climate-related flood hazards on sale of real estate.
• Under Goal SN-9, add policy: Explore partnering with or creating a workforce development program for installation and maintenance of urban greening features. • Under Goal SN-12, add policy: Explore creating a program to monitor buildings near contaminated sites exposed to shallow groundwater for intrusion of volatile organic compounds into sewer laterals.

Thank you for the opportunity to comment the draft Safety Element. We look forward to collaborating with East Palo Alto on flood resilience and nature-based shoreline protection.

Sincerely,
Erin Pang
Policy Manager
Save The Bay
248
Status key: Addressed = substantially reflected in the draft; Partial = partially addressed with gaps; Gap = not addressed in current draft.

Infrastructure, Services, and Facilities (ISF) Element
Commenter: Nuestra Casa
Policy Policy Summary Commenter Comment /
Recommendation
Status Staff Notes
Goal ISF-2. Ensure a Sustainable, Clean, Long-Term Water Supply Policy

2.1 Water Planning —
continue to
maintain a Water
System Master
Plan, Urban Water
Management Plan,
and water supply
blueprint
Nuestra
Casa
Policy 2.1 commits to
maintaining key water
planning documents
but includes no
strategy to improve
community
understanding of or
input into the Water
System Master Plan.

Recommend
developing an
outreach strategy such
as dedicated public
sessions to explain the
Master Plan, regular
updates on its
implementation, and
plain-language
summaries — modeled
on the community
engagement approach
used for the East Palo
Alto Parks Master
Plan, which partnered
with Nuestra Casa and
other CBOs for
surveys and focus
groups.

Partial, no
policy
change
Could expand on Policy

2.11 to include outreach,
information on water
sources and references
to Water System Master
Plan and where to locate
(city website). Also
covered in other policies.

Policy

2.2 Water Supply
Infrastructure —
continue to
improve
infrastructure to
ensure provision of
a clean, reliable
citywide water
supply sufficient to
serve existing and
planned
development
Nuestra
Casa
Given the scale of
infrastructure needs
outlined in Policy 2.2,
the draft Element
should include policies
that direct staff to
actively pursue
external funding
opportunities —
specifically state
sources such as the
SAFER program,
Drinking Water State
Revolving Fund
(DWSRF), and Climate
Bond. Nuestra Casa
offers to collaborate on
community-centered
funding applications
that draw on their trust
Addressed Policy 5.3 satisfies this
comment.

No further action
needed.
249
Policy Policy Summary Commenter Comment /
Recommendation
Status Staff Notes
with residents to
develop strong,
compelling proposals.

Policy

2.2 Water Supply
Infrastructure
(distribution
network)
Nuestra
Casa
Highlight the need for
infrastructure
improvements
specifically to the
distribution network —
the infrastructure most
residents interact with
and most want
improved. The
distribution network
ensures delivery of
quality water to
residents and should
be called out explicitly
alongside supply
infrastructure.

Addressed No further action
needed.

Policy

2.11 Public Education
about Water —
educate the public
in partnership with
BAWSCA and
community
partners regarding
water conservation,
water efficiency,
graywater use,
stormwater reuse,
water-efficient
planting, and other
conservation
efforts
Nuestra
Casa
Commend inclusion of
Policy 2.11 but
recommend expanding
scope beyond water
conservation to
include: (1) education
on drinking water
sources, water
monitoring methods,
and decision-making
structures to build
community trust; (2)
delivery of outreach in
a culturally relevant
manner with
multilingual resources;
(3) explicit partnership
with community-based
organizations such as
Nuestra Casa. Without
trust in the water
system, residents
remain skeptical of tap
water quality even
when the City is
improving
infrastructure. Cites the
February 2026 Nuestra
Casa water workshop
(40+ attendees, utility
manager present) as a
model for City-CBO
partnership.

References Valley
Water's robust water
Partial, no
policy
change
Include ‘CBOs’ but not
by name. City to commit
to providing brief
summaries in multiple
languages
250
Policy Policy Summary Commenter Comment /
Recommendation
Status Staff Notes
education program as
an example.

Goal ISF-5. Fund Construction and Maintenance of Basic Infrastructure and Public Facilities Policy

5.3 Grants and
Funding — pursue
grants and funding
sources that can
be directed
towards existing
deficiencies in
infrastructure and
facilities, including
regular
maintenance
Nuestra
Casa
Policy 5.3 is generic
and does not name
specific water-sector
funding programs. The
commenter
recommends the City
proactively identify and
pursue SAFER,
Drinking Water State
Revolving Fund,
Climate Bond, and
similar programs
specifically for water
supply and distribution
infrastructure
deficiencies.

Addressed Policy 5.3 satisfies this
comment.

Cross-Cutting Implementation — Applies Across All ISF Goals No new
policy/
IM
Needed
Add IM to ISF
Element (under
Goal ISF-2 or as a
standalone crosscutting IM):

Establish near-term
(0–3 year) and longterm (3+ year)
implementation
timeframes for all
ISF Element policies
and implementation
measures,
distinguishing
between actions that
can be initiated
immediately and
those dependent on
capital funding
cycles or external
processes.

Nuestra
Casa
Unlike the Safety
Element, the ISF
Element does not
consistently apply
implementation
timeframe labels to its
policies or IMs.

Nuestra Casa requests
clearly defined
timeframes to help
prioritize investments,
align with capital
investment cycles, and
provide transparency
to the community.

Cites Oakland's 2023
Safety Element (p. 5-1)
as a model.

Gap, but
no policy
action
Leave as is. Where
feasible and consistent
with available
resources/budget, the
implementation
measures with relative
timeframes could be
added. Timeframes are
intended as planning
guidance and are subject
to revision based on
funding availability,
capital planning cycles,
and City Council
priorities.

No new
policy/
IM
Needed
Add IM to ISF
Element (under
Goal ISF-5 or as a
cross-cutting IM):

The City shall
include an ISF
Element
implementation
update as part of the
annual General Plan
Status Report
required under
Government Code
Nuestra
Casa
Nuestra Casa
recommends the City
commit to an annual
progress report on ISF
Element
implementation
presented to Council
and publicly available
online, with clear
benchmarks, progress
toward goals, and
identification of
Addressed Comment is noted and
taken into consideration.

Annual GP progress
report already provided
to CC.
251
Policy Policy Summary Commenter Comment /
Recommendation
Status Staff Notes
§65400. The update
shall be presented
to the City Council,
posted on the City's
website, and shall
summarize notable
actions taken,
changes in
infrastructure
conditions, and
significant barriers
to implementation.
remaining gaps — to
track
accomplishments,
identify gaps, and build
community trust.

Safety and Noise Element
Commenters: PACT: (Nuestra Casa, El Concilio of San Mateo County Belle Haven Empowered, Climate Resilient Communities, Youth United for Community Action, SPUR), Save The Bay, Sierra Club Loma Prieta Chapter / Green Foothills / Citizens Committee to Complete the Refuge Policy Policy Summary Commenter(s) Comment /
Recommendation
Status Staff Notes
Goal SN-2. Reduce the Risk to People and Property from Earthquakes and Other Geologic Hazards
SN-2
Narrative
(p. 10-10)
Liquefaction hazard
description —
background section
explaining liquefaction
risk in the city
PACT Add note that sea
level rise and
groundwater rise
increase
liquefaction risk,
citing USGS
research. Provide
a more
explanatory
description of how
liquefaction
impacts homes
and infrastructure,
with an example
from past
earthquakes (e.g.,
SF Marina District
in 1989 Loma
Prieta).

Partial, No
policy
changes
Draft covers
liquefaction as a
seismic hazard but
does not crossreference
SLR/groundwater
linkage. Adding a
sentence to the
background
narrative requires no
policy change and
editorial revision
only.

Policy 2.4
/ SN-2.4
Site-Specific
Geotechnical
Investigations — require
geotechnical
investigations for new
construction in
liquefaction hazard
zones and tsunamiprone areas
PACT Add requirement
to include sea
level rise and
groundwater rise
projections in sitespecific
geotechnical
investigations,
consistent with
policies in the
emergent
Partial, no
policy
change
Reference Policy

4.1, 5.4 where
necessary. No policy
change
252
Policy Policy Summary Commenter(s) Comment /
Recommendation
Status Staff Notes
groundwater
section.

Goal SN-3. Provide Adequate Flood Control and Storm Drainage Facilities to Minimize the Risk of Flooding
SN-3
Narrative
(p. 10-14,
10-17)
Stormwater flooding
definition and
identification of major
flooding sources: high
tides, heavy rains, and
inadequate storm drain
system
PACT Revise stormwater
flooding definition
to include the role
of the shallow
groundwater table
and high tide
interaction. Identify
the Gardens
neighborhood
specifically as an
area experiencing
stormwater
flooding most
acutely.

Partial,
update
definition
Added Gardens
neighborhood.

Policy

3.10 Drainage and Flood
Control Systems —
integrate traditional
drainage with green
infrastructure
(bioswales, rain
gardens, permeable
surfaces)
PACT; Sierra
Club / Green
Foothills
Explore more
substantial
stormwater
systems to
complement GSI,
including large
holding ponds and
retention basins
(e.g., near
O'Connor Pump
Station). Develop
community
outreach plan
around bioswale
installations where
parking elimination
is required.

Partial, no
policy
change
Policy covers the
intent. Leave as is.

Policy

3.11 / IM

3.11a
Drainage Improvements
— establish regular
maintenance schedules
for storm drain
infrastructure.

Timeframe: Short-Term
PACT IM 3.11a should
specify designated
staffing and a City
budget
commitment, not
just a schedule, to
ensure
maintenance is
actually resourced.

Partial, no
policy
change
Recommend leaving
as is.

Policies

3.11 / 3.12
Drainage Improvements
and Storm Drain System
Upgrades — implement
Storm Drain Master Plan
(~$37.5M need
identified)
PACT Since the storm
drain system is the
only flooding
source the City
controls, and it
currently fails to
handle 10-year
storm events, the
Gap, no
policy
change
Neither 3.11 nor

3.12 directs staff to
pursue external
funding. In ISF 5.3
covers this
comment. Doesn’t
mention storm drain,
but intent is there.
253
Policy Policy Summary Commenter(s) Comment /
Recommendation
Status Staff Notes
Safety Element
must include a
policy or IM
committing to
actively seek and
secure
state/federal
funding to
advance critical
storm drain
upgrades. The
element should
also state how the
City plans to
finance the Storm
Drain Master Plan
and on what
timeline.

New policy
needed or
direct to a
regional
document
Add new policy under
Goal SN-3: Compound
Flooding Study —
conduct study to map
areas projected to flood
under future climatedriven rainfall, modeling
how future rainfall will
interact with rising sea
levels and groundwater
levels to inform the Storm
Drain Master Plan and
shoreline flood protection
projects.

Save The Bay No policy currently
directs a
compound
flooding study.

Future rainfall
patterns
interacting with
SLR and
groundwater rise
will change flood
risk across the city
in ways the current
Storm Drain
Master Plan
(2015) does not
reflect.

Gap, no
new policy
change
Edit 3.7 to include
regional partners,
OneShoreline.

New policy
needed
Add new policy under
Goal SN-3: Green
Stormwater Infrastructure
(GSI) Checklist —
implement a GSI checklist
for all capital projects to
ensure no missed
opportunities for
incorporating green
infrastructure. Design GSI
for multiple co-benefits:
flood resilience, urban
heat reduction, pollution
prevention, community
enhancement.

Save The Bay Policy 3.10
includes GSI
generally but does
not establish a
checklist or
systematic review
process for capital
projects. Without a
checklist, GSI
opportunities may
be missed during
CIP development.

Gap, may
need new
policy or
revise 3.10
Revise 3.10 to
include language
referencing green
infrastructure plan
and other green
infrastructure design
elements.

No action
needed
Add new policy under
Goal SN-3: Integrated
Flood-Resilient
Development Standards
— require new
development and
substantial improvements
Sierra Club /
Green Foothills;
PACT
Current policies
(3.10, 3.12, 4.1,

4.7) exist but are
not consolidated
into an
enforceable,
Addressed In the Development
Code, 50%
permeable front yard
areas are required
for single-family
zoning. C3/C6
stormwater
254
Policy Policy Summary Commenter(s) Comment /
Recommendation
Status Staff Notes
to incorporate integrated
flood and sea level rise
resilience measures
including Design Flood
Elevation (DFE), on-site
stormwater detention
sized for future
conditions, green
infrastructure, and
compound flooding risk
evaluation.
citywide
development
standard
framework.

Policies 3.10 and

3.11b remain
discretionary and
do not establish
specific,
predictable design
requirements. No
DFE standard is
established
citywide.
requirements
address runoff, new
construction
requires meeting
base flood elevation
and producing
elevation
certificates. Policy

4.1 and IM 4.1a
identifies updates to
the Floodplain
Management
Ordinance.

Recommendation no
further action
needed.

No action
needed
Add new policy under
Goal SN-3: Shallow
Groundwater and Sea
Level Rise Overlay
Districts — explore
creation of overlay
districts as a land-use tool
to create specific design
and retrofit requirements
for underground
infrastructure, roadways,
and new development in
areas at risk of sea level
rise, groundwater rise,
and storm flooding.

PACT Goal SN-3 policies
do not include a
land-use overlay
district
mechanism.

Overlay districts
would make flood
and groundwater
risk standards
systematically
applicable to all
development in
affected areas
through the zoning
code.

Addressed Policies 4.1, IM

4.1a, 4.7, 5.3, 5.4
address concerns.

City uses FEMA
map for any
guidance for future
development.

Recommend no
action. City to use
other methods
outside of SE. e.g.

Resilience Districts
Goal SN-4. Protect the Community from Sea Level Rise Impacts through Adaptive Planning, Regional Coordination, and Resilient Infrastructure Development Policies

4.1, 4.7

4.1: Apply flood control
requirements to SLRvulnerable properties.

4.7: Require new private
development in SLR
zone to elevate
habitable areas above
projected SLR
elevations.

Save The Bay Support these
policies.

Recommend
implementing
Policy 4.1 and 4.7
by following
OneShoreline's
Policy Planning
Guidance for
creating SLR and
groundwater rise
overlay zones,
which provides
template language
for incorporating
flood resilience
standards into the
zoning code.

Addressed No further action
needed
Recommend no
action. City to use
other methods
outside of SE. e.g.

Resilience Districts
Policy 4.3
/ IM 4.3a
Resilient Siting and
Design for Critical
Facilities — site new
Save The Bay Support this
policy.

Recommend IM
Addressed Policy 1.11, 1.12,
and 1.14 addresses
255
Policy Policy Summary Commenter(s) Comment /
Recommendation
Status Staff Notes
critical facilities outside
SLR hazard zone; if
unavoidable, construct
to appropriate
standards. IM 4.3a:
adopt siting standards.

Timeframe: Short-Term.

4.3a adopt siting
standards
consistent with
SLR projections
and to be flood
resilient.

Resilient addresses
this comment.

No further action
needed
Policy 4.4
/ Policy

5.1 4.4: Integrate SLR into
Capital Improvement
Projects planning. 5.1:

Integrate emergent
groundwater into CIP
planning.

Save The Bay Support these
policies.

Recommend
implementing
through SLR
resilience
guidelines that all
CIPs in the SLR
zone should
adhere to, citing
San Francisco's
Sea Level Rise
Checklist as a
model.

Addressed Policies are present.

No further action
needed
Goal SN-4
(structure)
Single goal addressing
all SLR impacts —
short-term and long-term
combined
PACT Recommend
breaking Goal SN4 into two parts:
one goal to
address short-term
SLR impacts and
one to address
longer-term SLR
impacts, to create
clearer policy
direction and
implementation
timelines.

Addressed The current single
goal covers both
near-term and longterm SLR concerns.

Comment is noted.

No further action
needed
No action
needed
Add policy under Goal
SN-4: Require disclosure
of sea level rise and other
climate-related flood
hazards on sale of real
estate.

Save The Bay No real estate
disclosure policy
for SLR or flood
hazards exists in
the draft. Buyers in
flood-prone areas
may not be aware
of SLR risk.

Addressed Comment
acknowledged.

State law already
requires disclosure
of FEMA Special
Flood Hazard Areas
and OPC-identified
sea level rise
vulnerability zones
at every real estate
transaction through
the Natural Hazard
Disclosure
Statement (Civil
Code §1103.2). The
City's authority to
require additional
disclosures beyond
state law is limited.

No further action
needed.
256
Policy Policy Summary Commenter(s) Comment /
Recommendation
Status Staff Notes
Goal SN-5. Safeguard Residents and Infrastructure from Emergent Groundwater Hazards While Preventing Contamination Mobilization
Policy 5.2 Development
Requirements in
Emergent Groundwater
Areas — encourage
construction and
substantial
improvements in areas
at risk of emergent
groundwater to conduct
geotechnical
investigations
PACT; Sierra
Club / Green
Foothills
Replace
'encourage' with
'require' for
geotechnical
investigations.

Extend coverage
to areas where
groundwater is
'very shallow' or
within 3.3 feet of
the surface (Figure
10-9), not just
currently mapped
emergent
groundwater
areas. Establish
measurable
triggers for action
such as
groundwater depth
thresholds and
flood event
frequency.

Partial, no
additional
policy
Comment noted.

City will continue to
work with
OneShoreline as
stated in Policy 4.2.

No changes.

Policy 5.4 Geotechnical
Assessment and
Mitigation for Emergent
Groundwater Areas —
require geotechnical
investigation and project
measures for new
development or
redevelopment in
mapped emergent
groundwater areas
PACT; Sierra
Club / Green
Foothills
Clarify the
difference
between 5.2
('encourage') and

5.4 ('require'). Add
language requiring
investigations in
areas where
groundwater is
'very shallow'
(within 3.3 ft of
surface) in
addition to
currently mapped
emergent areas.

Add screening
criteria and
measurable
thresholds to
guide when
investigation,
mitigation, and
monitoring are
triggered.

Partial, no
additional
policy
Comment noted.

City will continue to
work with
OneShoreline as
stated in Policy 4.2.

No changes.

Policy 5.5 Contaminated Site
Cleanup in Emergent
Groundwater Areas —
coordinate with CUPA,
DTSC, and SWRCB to
PACT; Save
The Bay
Support this
policy. Strengthen
by adding: (1)
require vapor
intrusion screening
Partial,
update
language
Comment noted.

Add language to
coordinate with
CBOs for site and
specific projects.
257
Policy Policy Summary Commenter(s) Comment /
Recommendation
Status Staff Notes
prioritize cleanup of
contaminated sites in
emergent groundwater
areas; emphasis on EJ
communities
for sensitive uses
including housing,
schools, and
childcare facilities
on or adjacent to
affected sites; (2)
state a clear
preference for full
cleanup over longterm exposure
management
strategies; (3)
recommend close
partnership with
YUCA, Nuestra
Casa, and CRC in
implementation.

Also Environmental
Protection Agency
as coordination
partner.

No new
policy
needed
Add new policy under
Goal SN-5: Groundwater
Risk Assessment and
Response Framework —
establish screening
criteria to determine when
geotechnical and
hydrologic investigation is
required, and defined
thresholds to guide
mitigation and monitoring
based on investigation
findings. Evaluate under
current and projected
future conditions.

Sierra Club /
Green Foothills
Current policies

5.2 and 5.4 do not
establish a
pathway for
determining when
investigation is
required as
conditions evolve
over time, or how
to translate
investigation
results into
consistent
mitigation
requirements. This
leaves uncertainty
about applicability
as groundwater
rises beyond
currently mapped
areas.

Addressed Maps will be revised
as SE is updated
every 8 years. No
change.

Goal SN-12. Protect Community Health and Safety from Hazardous Materials Exposure through Responsible Management, Remediation, and Prevention
Policy

12.1 / IM

12.1a
Contamination — avoid
or minimize risk from
exposure to
contaminated soils or
groundwater. IM 12.1a:
maintain database with
CUPA; hold public
multilingual workshops.

Timeframe: Short-Term
(Ongoing).

Save The Bay;
Sierra Club /
Green Foothills
Support this
policy.

Recommend
building on the
contaminated-site
database by
creating a publicly
accessible
tracking tool that:
maps
contaminated sites
and emergent
groundwater
areas; identifies
Partial Comment noted.

Policy already states
sharing database
with community and
holding community
workshops. No
change.
258
Policy Policy Summary Commenter(s) Comment /
Recommendation
Status Staff Notes
priority sites by
exposure risk and
EJ considerations;
tracks remediation
status and
timelines; and
identifies
responsible
departments and
contacts.

Policy

12.5 Prohibit Hazardous
Facilities in Groundwater
Areas — prohibit new
hazmat facilities in
emergent groundwater
areas as shown on
Figures 10-9 and 10-10
PACT Operationalize the
prohibition through
business licensing
and land-use
permitting screens
so the prohibition
is applied at the
point of application
review, not just
stated as a policy
goal.

Addressed Comment noted.

City’s current
process is to assess
each property as
each project is
presented. No
further action
needed. Already
included in best
practices.

Policy

12.7 Mitigate Hazardous
Material Risks from
Groundwater — require
existing facilities in
emergent groundwater
areas that handle
hazardous materials to
implement
comprehensive
monitoring, containment,
and emergency
response; establish
relocation/decommission
requirements
PACT Strengthen by: (1)
requiring
contamination
investigation and
cleanup plans to
be reviewed and
approved before
any grading or
earthwork begins;
(2) developing a
long-term
monitoring plan for
sites where full
remediation has
not been
achieved,
committing to best
available science
to detect and
respond to
contaminant
remobilization over
time.

Addressed No further action,
already required in
best practices.

New policy
needed
Add new policy under
Goal SN-12: Life
Sciences and Laboratory
Safety Standards —
develop and implement
standards and review
procedures for laboratory
and research uses,
including biosafety level
(BSL) standards (limit to
BSL-1 and BSL-2; prohibit
Sierra Club /
Green Foothills
Goal SN-12
addresses
hazardous
materials broadly
but does not
address the
distinct safety
considerations of
life sciences and
laboratory uses,
Addressed In the RBD, BSL-1,
and BSL-2 are either
approved by right or
administratively
approved. BSL-3
only through CUP.

BSL-4 not allowed.

Subject to findings
by staff that the
proposed use is
adequately buffered
259
Policy Policy Summary Commenter(s) Comment /
Recommendation
Status Staff Notes
or require EIR for BSL-3
and BSL-4), land use
compatibility with
sensitive receptors, and
required safety planning.

Relevant to East Palo Alto
given Menlo Park
settlement agreement re:
1005 O'Brien / 1320
Willow Road projects.
including
biological hazards
and specialized
waste streams.

The Menlo Park
settlement
agreement makes
this directly
relevant to East
Palo Alto.
from residential uses
and will be subject
to an annual safety
compliance
inspection by the
relevant County
agency and/or the
Fire Department. No
further action,
New policy
needed
Add new policy under
Goal SN-12: VOC Sewer
Lateral Monitoring —
explore creating a
program to monitor
buildings near
contaminated sites
exposed to shallow
groundwater for intrusion
of volatile organic
compounds into sewer
laterals.

Save The Bay No current policy
addresses VOC
intrusion into
sewer laterals
from shallow
groundwater
exposure near
contaminated
sites. This is a
specific and
understudied
pathway for
community
exposure.

Gap, add
new policy
Comment noted.

Staff sees this as an
emerging issue in
environmental
science.

New policy 12.7c to
state staff to comply
with all state
requirements
pertaining to sewer
discharge and
update sewer
management plan in
accordance with
State Water Board.

Cross-Cutting Implementation — Applies Across All Goals No new
policy
needed
Add implementation table
identifying lead and
supporting departments
responsible for each
Safety Element policy,
consistent with Oakland
2023 Safety Element
model (p. 5-1).

Recommend
development as a postadoption Implementation
Matrix companion
document.

PACT Draft does not
assign
departmental lead
or support to
individual policies.

Without clear
accountability,
coordination
across City
departments and
with external
agencies (MPFPD,
CUPA,
OneShoreline)
may be
inconsistent.

Gap, no
policy
action
needed
Comment noted.

This request can
vary and is
dependent on fiscal
budget and
Council’s direction.

Assignments may
change over the
course of the
lifecycle of this
document. Leave as
is.

No new
policy
needed
Add implementation
timeframe labels (shortterm 0–3 yr, medium-term
3–5 yr, long-term 5–8 yr)
to all Safety Element
policies and
implementation
measures.

PACT The draft applies
timeframe labels
selectively on
some IMs but not
consistently
throughout. No
medium-term
category exists.

Systematic
timeframe labeling
helps prioritize
investments and
Gap, no
policy
action
needed
Where feasible and
consistent with
available resources,
the City could
provide
implementation
measures with
relative timeframes.

Timeframes are
intended as
planning guidance
and are subject to
revision based on
260
Policy Policy Summary Commenter(s) Comment /
Recommendation
Status Staff Notes
provides
transparency.
funding availability,
capital planning
cycles, and City
Council priorities. No
Changes.

No new
policy
needed
Add policy or IM
committing to annual
progress report on Safety
Element implementation,
presented to City Council
and made publicly
available on the City's
website.

PACT No policy commits
to annual public
progress reporting
on Safety Element
implementation.

Reporting would
help track
accomplishments,
identify gaps, and
build community
trust.

Addressed Already required in
broad terms under
Government Code
§65400, which
mandates an annual
General Plan
progress report.

Where feasible and
consistent with
available resources,
the City could
provide
implementation
measures with
relative timeframes.

Timeframes are
intended as
planning guidance
and are subject to
revision based on
funding availability,
capital planning
cycles, and City
Council priorities. No
Changes.

New policy
needed
Add new policy under
Goal SN-9 or Goal SN-8:

Workforce Development
for Urban Greening —
explore partnering with or
creating a workforce
development program for
installation and
maintenance of urban
greening features and
green stormwater
infrastructure.

Save The Bay No policy connects
the green
infrastructure and
urban greening
work called for
throughout Goal
SN-3 and SN-8 to
local workforce
development. This
would create cobenefits: flood
resilience
investment and
local job creation.

Gap, could
address in
EJ
Element
Comment noted.

Explore addressing
in EJ.

New policy
needed
Add policy under Goals
SN-3/SN-4/SN-5: Unified
Citywide Standards
Integration — establish a
coordinated, citywide
approach to applying
development and safety
standards consistently
across all City plans, with
consistent triggers,
requirements, and review
procedures that align with
and extend the standards
Sierra Club /
Green Foothills
Strong
development and
safety standards
exist in the 2024
RBD Specific Plan
but apply only to
that area. The
Safety Element
does not extend
these citywide,
creating uneven
protection. This
Gap, no
policy
action
needed
Where feasible and
consistent with
available resources,
City Council may
direct staff to
conduct a review of
existing City plans
and incorporate
consistent standards
citywide per Council
Priorities. No
Changes.
261
Policy Policy Summary Commenter(s) Comment /
Recommendation
Status Staff Notes
in the 2024
Ravenswood/4 Corners
Specific Plan.
fragmented
approach reduces
effectiveness.
262

MEMORANDUM
DATE April 2, 2026
TO Elena Lee, Planning Division Manager
Alvin Jen, Associate Planner
City of East Palo Alto
ADDRESS 1960 Tate Street
East Palo Alto, CA 94303
FROM Liza Debies, Associate Principal
PlaceWorks
SUBJECT Safety and Noise Element and Infrastructure, Services, and Facilities Element Update California Environmental Quality Act Exemption Memorandum Introduction

PURPOSE
This Exemption Memorandum shall serve as an evaluation of California Environmental Quality Act (CEQA) compliance for the City of East Palo Alto (City) General Plan Safety and Noise Element and Infrastructure, Services, and Facilities Element Update (proposed project). This Exemption Memorandum was prepared to present the findings resulting from the CEQA compliance review.

STATUTORY AUTHORITY AND REQUIREMENTS
Once a lead agency determines that an activity is a project subject to CEQA, the lead agency must determine whether the project is exempt from CEQA. State CEQA Guidelines, California Code of Regulations, Title 14, Section 15061(b)1 outlines the ways in which a project may be exempt. A project is exempt from CEQA if at least one of five criteria is met:
1) The project is exempt by statute (see, e.g., Article 18 of the State CEQA Guidelines, commencing with Section 15260).
2) The project is exempt pursuant to a categorical exemption (see Article 19, commencing with Section 15300) and the application of that categorical exemption is not barred by one of the exceptions set forth in Section 15300.2.

1 California Association of Environmental Professionals. 2025. 2025 California Environmental Quality Act (CEQA) Statute and Guidelines. https://www.califaep.org/docs/CEQA_Handbook_2025combined.pdf. 263

SAFETY AND NOISE ELEMENT AND INFRASTRUCTURE, SERVICES, AND FACILITIES ELEMENT UPDATE

CALIFORNIA ENVIRONMENTAL QUALITY ACT EXEMPTION MEMORANDUM March 2026 | Page 2
3) The activity is covered by the common-sense exemption that CEQA applies only to projects that have the potential to cause a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA.
4) The project will be rejected or disapproved by a public agency (see Section 15270(b)). 5) The project is exempt pursuant to the provisions of Article 12.5 of Chapter 3.

The proposed project would be exempt as a common-sense exemption under CEQA Guidelines Section 15061(b)(3) because implementation of the proposed project would not have the potential to cause a significant effect on the environment (criteria 3), as further discussed in Findings Concerning CEQA Exemption.

Project Description

REGIONAL LOCATION
The city is in the southern portion of San Mateo County. The city is approximately 2.6 square miles and is bordered by the Ravenswood Open Space Preserve (in Menlo Park) and the San Francisco Bay to the east, the city of Menlo Park to the north and west, and San Francisquito Creek and the city of Palo Alto to the south. U.S. 101 connects East Palo Alto to other San Mateo County communities and points beyond. State Route (SR) 109/ University Avenue connects East Palo Alto to SR-84, which provides access to the East Bay and connections to the Central Valley.

PROPOSED PROJECT
Project Background
The Safety Element is a State-mandated policy document that is a component of the General Plan. The Safey Element identifies potential hazards that could affect community welfare, public health, and overall safety. The purpose of the Safety Element is to identify potential hazards and prepare a framework for the community to minimize risks and harm resulting from these hazards. In the East Palo Alto General Plan (Vista 2035), Chapter 9, Infrastructure, Services, and Facilities Element (which includes some safetyrelated topics), and Chapter 10, Safety and Noise Element (which covers most issues that State law requires in a Safety Element) were adopted in October 2016.

Safety Element and Infrastructure, Services, and Facilities Element Update The proposed project provides a policy framework for addressing emergency preparedness and response, seismic and geologic hazards, flooding, dam failure, sea level rise, emergent groundwater, fire hazards, severe weather and drought, transportation hazards, and human health hazards related to air quality. The proposed project also includes goals and policies addressing stormwater drainage, water supply, telecommunications, and solid waste, and climate change adaptation. An Existing Conditions Background Report, which discusses the natural and human-caused hazards that can affect the city, and a Climate Change Vulnerability Assessment, which includes an analysis of how climate-related hazards may harm the community, have been prepared, and will be included as appendices to the General Plan. The focus of the updates to the Safety Element is to address safety-related topics. There are updates to the 264

SAFETY AND NOISE ELEMENT AND INFRASTRUCTURE, SERVICES, AND FACILITIES ELEMENT UPDATE

CALIFORNIA ENVIRONMENTAL QUALITY ACT EXEMPTION MEMORANDUM March 2026 | Page 3
Infrastructure, Services, and Facilities Element because it contains some topics that are relevant to safety issues (e.g., stormwater systems, water supply, and emergency infrastructure resilience). Updates to the Safety Element and these other focused updates were made so that all safety-related topics are up to date and consistent with State law, per California Government Code Sections 65302(g) and 65302.15.2 Findings Concerning CEQA Exemption
SECTION 15061(B)(3): COMMON-SENSE EXEMPTION
The proposed project is exempt as a common-sense exemption under State CEQA Guidelines Section 15061(b)(3). This exemption applies because the proposed project does not have the potential to cause a significant effect on the environment.

ANALYSIS IN SUPPORT OF FINDINGS
The proposed project is a program-level policy document that includes goals, policies, and programs intended to guide decisions regarding land use, emergency operations and evacuation planning, and climate change adaptation, to ensure that communities are prepared for potential threats and can respond effectively when hazardous events occur. The proposed project establishes a framework for how to achieve its goals through policies and actions to improve public health and safety by complying with new State laws, incorporating policies from other local and regional plans, and responding to community goals and priorities. The proposed project does not include land use or zoning changes that would result in direct or indirect growth or changes in building density and intensity. The proposed project would not implement provisions that would result in direct or indirect population growth and thus would not place additional demands on natural resources, public services, or infrastructure. In addition, the proposed project does not include any site-specific designs or proposals to develop specific projects, nor does it grant any entitlements for development projects.

East Palo Alto City CouncilJune 2, 2026

East Palo Alto City Council
June 2, 2026